CLEARANCES

Deathbed IHT scheme succeeded due to HMRC procedural failing.

After an uneventful Budget and Tax Administration and Maintenance Day, and with little by way of legislative proposals (except for those advising non-doms), some of the most interesting tax developments of recent months have come in the form of...

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.