Commentary

D9.120 Application for a clearance

Corporate tax
Corporate tax | Commentary

D9.120 Application for a clearance

Corporate tax | Commentary

Clearance procedure

D9.120 Application for a clearance

A person who is in doubt whether transactions which he has carried out (or proposes to carry out) may give rise to counteraction may apply to HMRC for a 'clearance', ie a statement that those provisions shall not apply to him in respect of those transactions1. In practice, clearances are also dealt with by appointed HMRC officers in the Clearance and Counteraction Team, which also deals with, inter alia, clearances under the following provisions:

  1.  

    (a)     CTA 2010, s 1091 (demergers), see D6.429;

  2.  

    (b)     CTA 2010, s 1044 (company purchase of own shares),

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