Skip to content
Solved
SearchBrowse
Sign in

Contents

Official guidance
Advance Tax Certainty Service

ATCS08000 · Low-risk view on unallowable purpose rules in the loan relationships and derivative contracts regimes

  • ATCS08100 · General
  • ATCS08200 · What a low-risk view is
  • ATCS08300 · How to apply for a low-risk view
  • ATCS08400 · Request email
  • ATCS08500 · Early engagement meeeting
  • ATCS08600 · Application for low-risk view
  • ATCS08700 · Scoping and planning meeting
  • ATCS08800 · How a low-risk view will be issued and what to expect
  • ATCS08900 · Low risk view format and contents
  1. Low-risk view on unallowable purpose rules in the loan relationships and derivative contracts regimes: contents
  2. Low-risk view on unallowable purpose rules in the loan relationships and derivative contracts regimes: what a low-risk view is

ATCS08200 | Low-risk view on unallowable purpose rules in the loan relationships and derivative contracts regimes: what a low-risk view is

From HM Revenue & Customs · Advance Tax Certainty Service

A low-risk view is HMRC’s view that there is a low risk of future compliance intervention in relation to the unallowable purpose rules in the loan relationships and/ or derivative contracts regimes. A low-risk view is an indication, not a guarantee, of HMRC’s view when risk assessing a return.

It does not constrain future action by HMRC. In particular, it presents no impediment to HMRC opening an enquiry into any return or challenging any part of a return.

Depending on the nature of the view and the relevant international frameworks, information relating to a low-risk view may be exchanged with other tax administrations where required or appropriate.

Where applicable, a low-risk view is not a statement of the overall Business Risk Rating (low or non-low) of a particular Large Business customer.

PreviousNext
PrivacyTerms