ATCS05040 - Advance Tax Certainty Service: Process: Issuance: Clearance format and contents
Clearances will include the following core elements:
- basic information (customer details, reference number, and date of issue)
- matter(s) to which the clearance relates (summary of the issue(s) and scope)
- HMRC's position (confirmation of agreement or disagreement with the proposed tax treatment)
- key facts, assumptions and conditions
- duration and time-bound validity (typically up to 5 years, with conditions for renewal)
- monitoring and reporting (any annual reporting obligations or triggers for review)
- reliance and limitations (statement of binding effect and disclaimer(s))
- any market or commercial sensitivity flags
- confirmation governance checks have been completed
Clearances will not include tax advice or recommendations on how to structure transactions.