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HMRC internal manual

Capital Gains Manual

Targeted rules to prevent income to capital converter schemes by companies - terms of informal clearance

A clearance will state the terms on which it has been given, provided the relevantunderlying facts and legislation remain unchanged. HMRC will regard itself bound by aclearance as long as:

  • all relevant facts are accurately given, and
  • (where the clearance is given in advance of the execution of the relevant transaction or transactions) the transaction is executed in accordance with the proposals set out in the clearance application.