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HMRC internal manual

International Manual

Arbitrage: practical guidance: case identification and working of enquiries: submissions to the arbitrage team in CSTD Business, Assets & International

Issue of an arbitrage notice

For the arbitrage legislation to apply to a scheme, HMRC must issue a Notice (see INTM596510 and the legislation at F2A05/S24(1) and F2A05/S26(1)) stating that the Conditions in F2A05/S24 and F2A05/S26 apply.

Officers in the Large Business Service or Local Compliance running enquiries into the self-assessments of companies to which the arbitrage legislation would appear to apply should make a submission to the arbitrage team in CSTD Business, Assets & International through their International Issues Managers (Helen Cormack for LBS enquiries and Margaret Neighbour for Local Compliance enquiries)) setting out the facts of the scheme, the arguments put forward by the company or their agents, and their own views and comments, in a similar format as that required for arbitrage clearance applications. See INTM596560 and INTM596570).

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Technical advice

Technical advice on the workings of the arbitrage legislation, tax treatment in overseas territories, procedural matters, etc, should in the first instance be sought from the International Issues Manager (as above).

IIMs should seek technical advice from the arbitrage team in CSTD Business, Assets & International as required.