Commentary

D9.121 Effect of a clearance

Corporate tax
Corporate tax | Commentary

D9.121 Effect of a clearance

Corporate tax | Commentary

D9.121 Effect of a clearance

Where HMRC have given a clearance, they are precluded from taking counteraction under CTA 2010, s 746 (for corporation tax purposes) or ITA 2007, s 698 (for income tax purposes) in respect of the transactions notified in the clearance application1. The clearance does not extend to arrangements which include the notified transactions and other transactions not included in the application2. Where the information supplied (in the application or in response to HMRC enquiries) does not make a full and accurate disclosure of all facts and considerations relating to them which are material to be known

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