CG44156 - Targeted rules to prevent income to capital converter schemes by companies - format of clearance application

The following basic information should be contained in a clearance application:

Details of scheme participants

Company in which gain arises

• Name of company (and details of UK permanent establishment if overseas)
• Name of ultimate UK parent (if member of a group)
• Nature of the business of company
• UK Tax office and reference number
• Connection (if any) to other participants

Company in which income deduction arises OR in which an income receipt would have arisen in the absence of the arrangement

• Name of company (and details of UK permanent establishment if overseas)
• Name of ultimate UK parent (if member of a group)
• Nature of the business of company
• UK Tax office and reference number (where applicable)
• Connection (if any) to company in which gain arises and other participants

Other participants

• Name of each company (and details of UK permanent establishment if overseas)
• Name of ultimate UK parent of each company (if member of a group)
• Nature of the business of each company
• Territory of residence of each company
• UK Tax office and reference number of each company (where applicable)
• Connection (if any) to other participants

Details of the scheme

• Title, if any, of the arrangements
• Summary of the proposal or arrangements
• Explanation of each element in the arrangements from which the capital gain and the reduction of income profits arise
• Statutory provisions relevant to those elements of the arrangements from which a tax advantage arises
• Explanation of any commercial purpose for the arrangements