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HMRC internal manual

Capital Gains Manual

Targeted rules to prevent income to capital converter schemes by companies - notices - 90 day period

Once a notice has been issued, the taxpayer has 90 days to consider what effect thelegislation has on its tax liability in the same way as it would consider any otherrelevant tax legislation. Although HMRC will set out its view of the effect of thelegislation in the notice, the taxpayer should base its self-assessment on its own opinionof its tax liabilities, in the same way as it must apply all other relevant taxlegislation.