The following Corporation Tax guidance note Produced by Tolley provides comprehensive and up to date tax information covering:
There are three main types of clearances available:
HMRC will usually respond within 30 days for statutory clearance applications and within 28 days for non-statutory clearances, though this can take longer in more complex cases. Companies and their advisers should note that it is possible for clearance to take much longer than the normal turnaround. Indeed, in ‘Delays ahead’ in Taxation, 4 March 2021, 18, Pete Miller discusses his own recent experience of delays in HMRC granting statutory clearance under TCGA 1992, s 138, sometimes even in the case of simple reconstructions. Advisers should be aware of the potential of encountering similar delays with HMRC and factor these into the relevant transaction timetable.
Statutory clearances are clearance procedures provided for in the legislation. There are a number of statutory clearances available. Some of these are dealt with regularly by tax advisers and so these are covered in more detail below.
Clearances under the following provisions shoul
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‘Hold-over’ relief allows for the deferral of a gain that would otherwise arise in relation to a disposal. No capital gains tax (CGT) is due in respect of the disposal, but the base cost of the asset for the transferee for the purpose of a future disposal is reduced by an amount equal to the gain
Income and gains may be taxable in more than one country. The UK has three ways of ensuring that the individual does not bear a double burden:1)treaty tax relief may reduce or eliminate the double tax 2)if there is no treaty, the individual can claim ‘unilateral’ relief by deducting the foreign tax
Maintenance payments are payments made by a taxpayer to their former or separated spouse for the maintenance of that former spouse or their children. To obtain any tax relief for maintenance payments, one of the couple must have been born before 5 April 1935 and the payments must be made by virtue
Preparatory workBefore completing the Inheritance Tax account for submission to HMRC, the practitioner needs to undertake a comprehensive review of the extent of the estate and its proposed distribution. The work required leading up to the submission of the account is described in detail in the
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