Transcription of Statutory Clearances om Fr HMRC - …
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Statutory Clearances om Fr HMRC - …
ISSUE 87 | JULY 10, 2014 FEATURED ARTICLES Statutory Clearances From HMRC by Pete Miller CTA (Fellow), Partner, Th e Miller Partnership Contact: and +44 116 208 1020; website: Th e UK's tax legislation provides for formal clear-ances from HM Revenue & Customs (HMRC) in a number of situations. HMRC also operates an infor-mal system of non- Statutory Clearances , available to all "business customers." Th is article is about statu-tory Clearances , but much of it would apply to non- Statutory Clearances , too. Th ere is useful advice on HMRC's website at Th e most common Statutory Clearances are those for share exchanges (s138, Taxation of Chargeable Gains Act 1992 (TCGA 1992)), schemes of recon-struction (ss138, 139(5), TCGA 1992), share buy-backs (s1045, Corporation Tax Act 2010 (CTA 2010)), demergers (s1091, CTA 2010, which I once worked on while at the Inland Revenue, one of the predecessor bodies to HMRC), and transac-tions in securities (s701, Income Tax Act 2007).
a reference and a date by when you should have a substantive answer. If you receive one of these, it does not mean that HMRC wants to refuse your
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