SolvedCG44156 | Targeted rules to prevent income to capital converter schemes by companies - format of clearance application
From HM Revenue & Customs · Capital Gains Manual
The following basic information should be contained in a clearance application:
Details of scheme participants
Company in which gain arises
Name of company (and details of UK permanent establishment if overseas)
Name of ultimate UK parent (if member of a group)
Nature of the business of company
UK Tax office and reference number
Connection (if any) to other participants
Company in which income deduction arises OR in which an income receipt would have arisen in the absence of the arrangement
Name of company (and details of UK permanent establishment if overseas)
Name of ultimate UK parent (if member of a group)
Nature of the business of company
UK Tax office and reference number (where applicable)
Connection (if any) to company in which gain arises and other participants
Other participants
Name of each company (and details of UK permanent establishment if overseas)
Name of ultimate UK parent of each company (if member of a group)
Nature of the business of each company
Territory of residence of each company
UK Tax office and reference number of each company (where applicable)
Connection (if any) to other participants
Details of the scheme
Title, if any, of the arrangements
Summary of the proposal or arrangements
Explanation of each element in the arrangements from which the capital gain and the reduction of income profits arise
Statutory provisions relevant to those elements of the arrangements from which a tax advantage arises
Explanation of any commercial purpose for the arrangements