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HMRC internal manual

Venture Capital Schemes Manual

VCT: VCT qualifying holdings: requests for advance assurance: dealing with requests

Although this procedure is not statutory, HMRC is normally bound by any assurance given where the information supplied was correct and complete at the time and has not been superseded by subsequent events. It is therefore important, in order to avoid misunderstanding, that all information provided is given in writing. For the same reason, it is also important that requests should be considered very carefully, in the light of both the information supplied and information available on the tax files of the investee company and any subsidiaries, before any decision is made. Companies seeking an assurance therefore need to allow adequate time for HMRC to consider the request properly.

Any assurance supplied to a company can only be given on the basis of the information provided. The HMRC officer is under no obligation to check the accuracy or completeness of that information. However, it is important that any obvious gaps in the information should be filled and any apparent contradictions explained, and the officer may ask further questions to ensure that that is the case.