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HMRC internal manual

Company Taxation Manual

Introduction: preface

Giving advice to companies

The Clearance Service for Businesses sets out the various ways in which HMRC aims to achieve its policy of helping business taxpayers. This, together with CAP 1 (Clearance and Approvals 1) for non-business taxpayers supersedes the previous COP 10 (Code of Practice 10).

Broadly the services include:

  • providing general advice,
  • giving ‘post-transaction rulings’,
  • providing HMRC’s interpretation of tax law in some circumstances,
  • giving statutory clearances and approvals for certain types of transactions.

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 requires referal to the appropriate Technical Adviser before taking up the matter with the company or its advisers. See ‘Technical Help’ on the left bar.

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. Again such cases should be referred to the appropriate Technical Adviser via ‘Technical Help’.

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.