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HMRC internal manual

International Manual

Arbitrage: practical guidance: case identification and working of enquiries: The arbitrage team in Business, Assets & International

Contact details for the arbitrage team in Business, Assets & International (BAI):

Andrew Martel
HM Revenue & Customs
Business Assets & International
Base Protection Policy Team
S1715, Floor 9, Mail Point 3

Central Mail Unit


NE98 1ZZ


In August 2010, responsibility for certain aspects of arbitrage work previously undertaken by CSTD Business, Assets & International (BAI) was transferred to the operational units in Large Business (LB) and ISBC. For all Customer Compliance Manager (CCM) cases the new point of contact for dealing with arbitrage clearance applications (see INTM596550) will be the CCM. For companies in ISBC without a CCM, the point of contact will be Margaret Neighbour, International Issues Manager (IIM) in ISBC.

BAI retain responsibility for all current work on hand at this date. BAI also retain responsibility for all work within the High Risk Corporates Programme and the Managing Corporate Risk Programme, the issue of Notices (see INTM596510) directing that the arbitrage legislation will apply, preliminary work on disclosures under the Avoidance Disclosure Regime, and will continue to offer technical support in connection with the workings of the arbitrage legislation and the running of enquiries into the returns of companies to which the arbitrage legislation is applicable.

Arbitrage is not within the transfer pricing governance structure.