CTM36860 | Particular topics: transactions in securities: clearance: internal communications

Where a company involved in the transactions has a Customer Compliance Manager Clearance and Counteraction Team will liaise with the CCM.

All clearance applications received elsewhere in HMRC should be forwarded immediately to Clearance and Counteraction Team. (This content has been withheld because of exemptions in the Freedom of Information Act 2000)

Advise the agent or company that you have done so in the following terms:

Thank you for your application for clearance under ITA07/S701 sent to me on [date]. All such applications must be made to the Clearance and Counteraction Team of HMRC and not to this address. Your application has been forwarded. The team may be contacted by email at [email protected] or by writing to

BAI Clearance
HMRC
BX9 1JL

Do not send any other papers with the clearance application.

(This content has been withheld because of exemptions in the Freedom of Information Act 2000)

Reporting cross-border transactions

The OECD/G20 Base Erosion and Profits Shifting (BEPS) initiative is designed to reduce international tax avoidance and includes a requirement to exchange information which extends to statutory clearances having cross-border effect. A statutory clearance for this purpose is an agreement made between a tax authority and a taxpayer which may be relied upon. Such 'rulings' with an international dimension are in principle exchangeable with another jurisdiction, either

• automatically under BEPS Action 5,

• automatically under the EU Directive on Administrative Cooperation in the field of Taxation ('DAC'), or

• spontaneously where it would foreseeably be of assistance to another jurisdiction.

IEIM500000+ onwards gives more information, including on whether, when, and how to exchange such rulings. Reference to the guidance on sharing rulings must be made before responding to an application with a cross-border element in case further information is needed. Where a clearance is issued by the Clearance and Counteraction Team they will pass details to the Joint International Taskforce on Shared Intelligence and Collaboration (JITSIC) in appropriate cases as part of the clearance process.