HMRC now routinely grants clearance for transactions for inserting new holding
companies, but it remains reluctant to do so for transactions inserting personal
investment companies.
Taxpayers increasingly need to rely on statements made by HMRC which do not have the force of law, such as HMRC clearances given to a taxpayer or HMRC guidance. In this back-to-basics guide, Christopher Harrison and David Stainer (Allen & Overy) provide an overview of the principles which govern a taxpayer’s ability to rely on written statements by HMRC, particularly on legitimate expectation.
Jeff Webber answers a query on whether a loan could be caught as a ‘chargeable payment’ under CTA 2010 s 1088.
William Arrenberg and Michael Alliston examine the tax implications of the different ways of effecting public takeovers and mergers.
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