Commentary

D6.204 Scheme of reconstruction—clearance procedure

Corporate tax
Corporate tax | Commentary

D6.204 Scheme of reconstruction—clearance procedure

Corporate tax | Commentary

D6.204 Scheme of reconstruction—clearance procedure

Before any issue of shares is made, any of the companies involved in the scheme of reconstruction may apply to HMRC for confirmation that the transactions will be effected for bona fide commercial reasons and not for tax avoidance (D6.202), giving full particulars of the proposed transactions1.

All applications for clearance should be sent to the Clearance & Counteraction Team, Anti-Avoidance Group. Their contact details can be found online2.

HMRC has 30 days in which to notify the applicant of its decision or request further information (which the applicant must supply within 30 days)3. Any clearance granted

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