Commentary

D6.441 Administration—Clearance applications for a management buy-out

Corporate tax
Corporate tax | Commentary

D6.441 Administration—Clearance applications for a management buy-out

Corporate tax | Commentary

D6.441 Administration—Clearance applications for a management buy-out

It is likely to be the vendor rather than the purchaser in an MBO transaction who will want to apply to HMRC for advance clearances or assurances. However, whilst clearance applications can be prepared and submitted by the vendor, the purchaser should be given a right to view them. The main clearance applications which the vendor may wish to make are listed below:

  1.  

    (a)     Clearance under TCGA 1992, s 138.

  2.  

    This clearance confirms that, on a company reconstruction within TCGA 1992, s 135 (D6.205), no capital gains tax charge will arise on the

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