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

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.