Commentary

D4.745 Tax arbitrage—clearance

Corporate tax
Corporate tax | Commentary

D4.745 Tax arbitrage—clearance

Corporate tax | Commentary

D4.745 Tax arbitrage—clearance

The provisions in this article were repealed from 1 January 2017. From 1 January 2017, the rules dealing with hybrid and other mismatches apply; see D4.701 onwards. The latter rules were introduced as part of the OECD BEPS action plan on international corporate tax avoidance.

HMRC have agreed to operate an informal clearance procedure, by way of requests for advice about the legislation, including whether the legislation will apply to a planned series of transactions that may constitute a scheme. Where possible, they will give a decision whether any notice will be issued in respect of the disclosed

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