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HMRC internal manual

Non-statutory Clearance Guidance

Avoidance indicators: indirect tax overview

An application for clearance may be rejected in certain circumstances. One such circumstance is where we take the view that the arrangements are primarily to gain a tax advantage rather than primarily commercially motivated.

Before a clearance application is rejected on avoidance grounds, advice should be sought from Counter Avoidance (CA).

More information about Counter Avoidance can be found on their website.

While the above link will help you get more information about known schemes, you should always bear in mind that what you are looking at could be the first example of a new scheme. It is therefore important to seek advice from AAG if you have concerns about an application, even if you can find no mention of it in the list of known schemes.