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HMRC internal manual

Advance Tax Certainty Service

ATCS08800 - Low-risk view on unallowable purpose rules in the loan relationships and derivative contracts regimes: how a low-risk view will be issued and what to expect

The decision to issue or decline a low-risk view will be made in accordance with applicable risk assessment processes. The decision will not require approval by the clearances approval board as this is not a decision in relation to a clearance.