ATCS08300 | Low-risk view on unallowable purpose rules in the loan relationships and derivative contracts regimes: how to apply for a low-risk view

It is intended that the process for application for a low-risk view will follow broadly the same steps as, and link into the process for, a clearance application under the Advance Tax Certainty Service, though this may be varied if this is required by very particular circumstances. A core principle is that if HMRC cannot obtain information and documents in an appropriate form and at appropriate times to assess the request, HMRC may decline to progress the request.

The same basis of engagement will apply as for the clearance application, including the importance of your being open and honest and fully disclosing all relevant facts. The following specific points will apply.