Flotations — HMRC clearances

Produced by Tolley in association with Anne Fairpo
Corporation Tax
Guidance

Flotations — HMRC clearances

Produced by Tolley in association with Anne Fairpo
Corporation Tax
Guidance
imgtext

Various tax clearances are generally applied for as part of (and prior to) flotation of a company including:

  1. TCGA 1992, s 138 clearance to confirm share for share exchange relief on a reorganisation / reconstruction in preparation for the flotation (see the Paper for paper treatment clearances guidance note)

  2. ITA 2007, s 701, and CTA 2010,

Continue reading the full document
To gain access to additional expert tax guidance, workflow tools, generative tax AI, and tax research, register for a free trial of Tolley+™
Anne Fairpo
Anne Fairpo linkedinicon twittericon

Barrister


With effect from 1 June 2021, Anne Fairpo is a judge of the First-tier Tribunal sitting in the Tax Chamber. She was previously a fee-paid judge in the same Chamber. Her contributions to LexisPSL Tax and TolleyGuidance were written before her full-time appointment and are her personal view as she is not authorised to write on behalf of the Tribunals Service or the judiciary. Until April 2021, Anne was a tenant at Temple Tax Chambers. She was called to the bar in 2009 after 15 years as a solicitor. Anne’s experience and expertise covers UK and international corporate tax planning and disputes, having acted for a range of clients from small owner-managed businesses to listed multinationals, as well as having advised on intellectual property taxation and UK-US cross-border tax planning, with regard to both direct and indirect tax matters

Powered by Tolley+
  • 11 Nov 2025 09:50

Popular Articles

Allowable expenses for property businesses

Allowable expenses for property businessesGeneral itemsMany of the principles applying to allowable expenses for property businesses are similar to those that apply for trading and the rules for individuals in a property business are generally the same as for companies with some exceptions which are

14 Jul 2020 13:26 | Produced by Tolley in association with Rob Durrant-Walker of Crane Dale Tax, part of AMS Group Read more Read more

Special rate pool and long life assets

Special rate pool and long life assetsSpecial rate poolExpenditure on some types of plant or machinery must, if neither annual investment allowance (AIA) nor first year allowances (FYAs) are available, be allocated to a ‘special rate pool’. Expenditure to be allocated to the special rate pool

14 Jul 2020 13:41 | Produced by Tolley Read more Read more

Simple assessments

Simple assessmentsFrom 2016/17 onwards, HMRC has the power to make a ‘simple assessment’ of the taxpayer’s income tax and / or capital gains tax liability outside of the self assessment system. As HMRC already receives significant amounts of information on the income received and tax paid by

14 Jul 2020 13:40 | Produced by Tolley Read more Read more