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HMRC internal manual

Non-statutory Clearance Guidance

Dealing with applications: application inconsistent with the policy intention of the legislation used: letters to be used

Where it is considered that the inconsistency with the policy intention gives rise to a tax advantage, we will decline to respond in line with our existing policy on tax advantage and issue template letter NSCG6250, including using the paragraph, ‘I suspect that the arrangements are primarily to gain a tax advantage’ along with any additional text provided by the policy owner.

In all other cases template letter NSCG6400 should be used with the policy lead’s response.