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HMRC internal manual

Capital Gains Manual

Targeted rules to prevent income to capital converter schemes by companies - informal clearances

Companies and their representatives may make requests for advice about the legislationin TCGA92/S184G to H, including whether the provisions will apply to a planned series oftransactions that may constitute an arrangement.

It is important that any request for advice is made on the basis of full disclosure of allrelevant facts, in order that any advice given may be relied upon.

HMRC will give advice concerning actual or proposed transactions. Where possible, we willconfirm that no notice will be issued in respect of the disclosed transactions. If theinformation disclosed is insufficient to enable us to reach a decision, we will say so andif possible indicate what further information should be provided.