Beta This part of GOV.UK is being rebuilt – find out what this means

HMRC internal manual

Capital Gains Manual

From
HM Revenue & Customs
Updated
, see all updates

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