CTM00505 - Introduction: preface

Giving advice to companies

HMRC will confirm its view of the tax treatment of transactions where there is genuine uncertainty about how the rules apply. The current procedure for obtaining non-statutory clearances is at

https://www.gov.uk/guidance/non-statutory-clearance-service-guidance

Clearances generally are dealt with at

https://www.gov.uk/guidance/seeking-clearance-or-approval-for-a-transaction

Uniformity of treatment

The guidance provides for uniformity of treatment between all taxpayers. However, a novel situation may arise or a new interpretation of the law or practice may seem appropriate to a matter which could become publicly sensitive. For example, an officer may wish to apply a decision to a whole class of taxpayers or a trade. (This content has been withheld because of exemptions in the Freedom of Information Act 2000) .

Cases where very substantial amount of tax in issue

It is essential that the Commissioners’ freedom to act is not restricted by the premature agreement of liability where a very substantial amount of tax is in issue. (This content has been withheld because of exemptions in the Freedom of Information Act 2000) .

United Kingdom

The expression ‘United Kingdom’ means Great Britain and Northern Ireland. It does not include the Irish Republic, the Isle of Man or the Channel Islands.