The Clearance and Counteraction Team is responsible both for the operational aspects of the anti-avoidance legislation at S748 CTA 2010 (Corporation Tax purposes only) S731-751 CTA 2010 and S682-713 ITA 2007 (Income Tax purposes only) and the statutory clearance provisions below. The team currently consists of nine direct tax specialists with a small support team.
The Clearance and Counteraction Team handles applications for statutory clearance under certain provisions in respect of transactions in securities, demergers, purchase of own shares by unquoted trading companies, and anti-avoidance rules on share/debenture exchanges, schemes of reconstruction, company reorganisations and transfers of trade between EU member states.
We also advise on all aspects of the anti-avoidance provisions in respect of Transactions in Securities (under S746 CTA 2010 and S698 ITA 2007). For other provisions where we operate the clearance procedures, however, we do not have technical responsibility for the areas of the legislation in question.
The team is also responsible for identifying and investigating transactions that potentially come within the scope of the anti-avoidance provisions at S746 CTA 2010 and S698 ITA 2007 and counteracting tax advantages obtained in consequence of such transactions.
