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HMRC internal manual

Capital Gains Manual

Targeted rules to prevent income to capital converter schemes by companies - clearance refused

Where a clearance cannot be given HMRC will state the reasons. If a company disagreeswith HMRC’s view on a clearance it is entitled to make its self assessment on its ownunderstanding of the law and how it applies to the facts given in the clearanceapplication. Should a notice under TCGA92/S184G or H subsequently be issued the companycan appeal in the normal way against any amendment to the self-assessment which HMRC maymake.