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HMRC internal manual

Non-statutory Clearance Guidance

Avoidance indicators: direct tax and NIC 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 or NICs advantage rather than primarily commercially motivated.

In the interests of consistency and before a clearance application is rejected on avoidance grounds, advice should be sought from the Counter Avoidance Group.

(This content has been withheld because of exemptions in the Freedom of Information Act 2000)