Commentary

D1.944 Corporate capital losses anti-avoidance—HMRC clearances

Corporate tax
Corporate tax | Commentary

D1.944 Corporate capital losses anti-avoidance—HMRC clearances

Corporate tax | Commentary

D1.944 Corporate capital losses anti-avoidance—HMRC clearances

HMRC operates an informal arrangement under which it will consider a request for advice about the possible application of the provisions described in D1.941, D1.942 to actual or proposed transactions1.

A clearance application should be made to:

HMRC

Clearance & Counteraction Team

CTIAA Clearance SO528

PO Box 197

Bootle

L69 9AA

The application should be marked 'Capital losses clearance application'.

HMRC would expect the application to include the details set out below.

Details of scheme participants

1. Company in which the gain arises:

  1.  

    (a)     Name of company (and details of UK permanent establishment if overseas)

  2.  

    (b)     Name of ultimate UK parent (if member of a group)

  3.  

    (c)     Nature of the business of the

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