ATCS08400 | Low-risk view on unallowable purpose rules in the loan relationships and derivative contracts regimes: request email
From HM Revenue & Customs · Advance Tax Certainty Service
Please state your request to apply for a low-risk view as an additional point in the request email described in ATCS04260, together with a brief description of:
which loan relationships and/ or derivative contracts the request applies to
which companies are party to them
what the arrangements as a whole are, and what the parts are in which the companies are involved