Commentary

D9.122 Duties and practice of HMRC

Corporate tax
Corporate tax | Commentary

D9.122 Duties and practice of HMRC

Corporate tax | Commentary

D9.122 Duties and practice of HMRC

There is no appeal from a refusal of clearance, and HMRC are under no obligation to give reasons for refusing a clearance. However, a refusal usually means that HMRC are not satisfied that the motives behind the transactions are within the escape clause (see D9.116) and the refusal letter will in practice usually state this and explain HMRC's concerns. Also, on most occasions the inspector dealing with the application will be willing to discuss his or her reasons relatively informally (usually by telephone). Such assistance can often be invaluable in helping taxpayers amend the

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