New clearance system should cover all taxes, says CIOT

The CIOT has responded to the Treasury consultation on advance tax certainty for major projects. Key points include:

• the new process should ensure a focus on key projects and issues that will impact investment decisions; it is accepted that any new clearance service cannot exhaustively provide certainty on every tax implication;
• the process should be expanded to cover taxes other than corporation tax where these are relevant to the particular project given that the largest most complex projects will have implications across the full range of taxes;
• HMRC will need to retain skilled resource to fulfil existing services while also ensuring that any new service is sufficiently and effectively resourced;
• while a clear quantitative threshold will provide clarity the need for clearance is derived from the level of uncertainty in relation to the tax treatment rather than the level of expenditure;
• the impacts of...