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HMRC internal manual

International Manual

From
HM Revenue & Customs
Updated
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Arbitrage: legislation and principles: procedures: Format of clearance application: receipts

HMRC would expect to receive the following basic information in a clearance application:

Receipts

A Details of scheme participants

  1. Company

 

 

  1. Name of company (and details of any branches including those in the UK)
  2. Name of ultimate UK parent (if member of a group)
  3. Nature of the business of company
  4. Territory of residence
  5. UK Tax office and reference number
  6. Connection (if any) to paying party and other participants
  7. Copy of most recent accounts

 

  1. Paying party

 

 

  1. Name of company (and details of any branches including those in the UK)
  2. Name of ultimate UK parent (if member of a group)
  3. Nature of the business of company
  4. Territory of residence
  5. UK Tax office and reference number (where applicable)
  6. Connection (if any) to company and other participants

 

  1. Other participants

 

 

  1. Name of each company (and details of any branches including those in the UK)
  2. Name of ultimate UK parent of each company (if member of a group)
  3. Nature of the business of each company
  4. Territory of residence of each company
  5. UK Tax office and reference number of each company (where applicable)
  6. Connection (if any) to other participants

B Details of the scheme

  1. Description of the proposed scheme
  2. Nature and amount(s) of all relevant transaction(s)
  3. Details of the tax deduction(s) (or other relief(s)/allowance(s)) available to the paying party and the territory in which each is available
  4. Explanation as to why the payment is not brought into account under FA96/S91A
  5. Explanation as to why the payment is not otherwise brought into account as income or gains.