Advance clearances or approvals may be given to some transactions
HM Revenue & Customs (HMRC) may be able to provide advance clearance or approval to some transactions. You will find here a list of some of those transactions and the addresses to which you should send your applications.
On this page:
You can find information on the clearance service offered by HMRC for customers and their advisers who need clarification on guidance or legislation in relation to a specific transaction by following the links below.
Clearance service for business - how to get certainty on significant business issues
Notification of company migration and approval of arrangements for payment of tax liabilities in accordance with Section 109B-F TMA 1970 (previously Section 130 Finance Act 1988) (see Statement of Practice 2/90).
Send applications for clearance to:
Neil Nagle
HM Revenue & Customs
CTIAA Business International, Transfer Pricing Team
100 Parliament St
London
SW1A 2BQ
Tel 020 7147 2459
Fax 020 7147 2649
Email Neil Nagle
Read Statements of Practice (PDF 1.4MB)
Clearances in relation to Controlled Foreign Companies in accordance with S747-756 and Schedules 24-26 Income and Corporation Taxes Act (ICTA) 1988.
Send applications for clearance to:
Mary Sharp
HM Revenue & Customs
CTIAA Business International
100 Parliament St
London
SW1A 2BQ
Tel 020 7147 2656
Fax 020 7147 2647
Email Mary Sharp
For confirmation that the rules of the scheme (other than those applying to the investing company) will be satisfied, under Schedule 15 FA 2000.
Send the request to:
Small Company Enterprise Centre
HM Revenue & Customs
1st Floor Ferrers House
Castle Meadow Road
Nottingham
NG2 1BB
Tel 0115 974 1250
Email Corporate Venturing Schemes
Under Schedules 2, 3 and 4, Income Tax (Earnings and Pensions) Act 2003, send applications for approvals of Share Incentive Plans, Savings-Related Share Option Schemes and Company Share Option Plans to the address shown at the link below.
Contact Employee Shares and Securities unit.
Statement of Practice 1/12, deals with Advance Thin Capitalisation Agreements. It replaces an earlier Statement of Practice 04/07.
The first contact for information about advance thin capitalisation agreements under the Statement of Practice should be the Customer Relationship Manager (CRM) for Customer Contact (CC) of the business concerned, and they will engage the assistance of a transfer pricing specialist. If there is no known CRM or CC, the application may be sent to the local Transfer Pricing team leader.
Otherwise, please address enquiries and applications through Ashley Culpin at CTIAA Business International.
Email Ashley Culpin
Read Statements of Practice (p338) (PDF 1.4MB)
More information on Inward Investment is available on this website.
Read about the Inward Investment Support service
All applications for advance clearance on Business Investment Relief Provisions should be sent to:
HM Revenue & Customs
Business Investment Relief Team S1278
PO Box 202
Bootle
L69 9AL
Tel 01274 444 535
Email Cameron Wilson
Under S444AED ICTA 1988.
Send all applications for clearance, including cases where the parties include non-UK resident companies or friendly societies to the transferor company's Customer Relationship Manager and to:
HM Revenue & Customs
CTIAA Corporation Tax and Business Income Tax
Financial Services Team
3rd Floor
100 Parliament Street
London
SW1A 2BQ
Tel 020 7147 0517
Fax 020 7147 2641
Email Christina Jacob
S590 and S591 ICTA 1988.
Occupational pensions, personal pensions, public sector schemes,
Free Standing Additional Voluntary Contributions schemes and ex-gratia
relevant payments
Send applications for approval to:
HM Revenue & Customs
Pension Schemes Services
FitzRoy House
Castle Meadow Road
Nottingham
NG2 1BD
Tel 0845 600 2622, from abroad + 44 115 974 1600
Fax 0115 947 1480
Email Pension Schemes Services
More about HMRC's Pension Schemes Services
Schedule 15 ICTA 1988.
Certification of qualifying life assurance policies
Send applications for approval to:
Claire Ritchie
HM Revenue & Customs
CTIAA Corporation Tax and Business Income Tax
Financial Services Team
3rd Floor
100 Parliament Street
London
SW1A 2BQ
Tel 020 7147 2586
Fax 020 7147 2641
Email Claire Ritchie
Under Sections 765 and S765A ICTA 1988:
The Treasury Consents regime was repealed by Finance Act 2009. Events or transactions taking place on, or after 1 July 2009 are subject to a new reporting regime, detail of which can be read in HMRC's International Manual at INTM700000.
Read the International Manual INT700000
HMRC's Clearance and Counteraction Team, Anti-Avoidance Group handles requests where advance clearance is required under statutory provisions relating to any one or more of the following:
Where clearance is required under any one or more of the above provisions then you should send a single letter to the Clearance and Counteraction Team, Anti-Avoidance Group at the address given below. No extra copy is required as the same person will deal with each of the clearances asked for. A single response will be given covering all of these.
Please make clear at the top of your letter what clearances you are asking for.
Please note the following points:
Please ensure you mark your application as 'Market sensitive' or 'Non market sensitive', as applicable, and send it to:
Clearance and Counteraction Team (Anti-Avoidance Group)
SO528
PO Box 194
Bootle
L69 9AA
Tel 020 7438 7474
Fax 020 7438 4409
Email Clearance and Counteraction Team
The Clearance and Counteraction Team does not handle applications for Stamp Duty Land Tax (SDLT) adjudications.
Read about obtaining HMRC advice on how SDLT will apply
Attachments to emails should be no larger than 2MB. Please don't send self-extracting zip files as HMRC software will block them.
Please note we cannot guarantee the security of emails you send to us or we send to you over the internet. Information sent by email over the internet is not secure and is at risk of being intercepted and read by people other than those it was intended for. Any information you send to us by email is at your own risk. If you would like us to reply by email, please confirm in your message that you understand and accept the risks involved. However, if our response to you contains any personal or confidential information we will only reply to you by letter or telephone.
If you have any doubt about the authenticity of an email you receive which claims to come from HMRC please do not follow any links within the email, disclose any personal details or respond to it. Forward it to us at: phishing@hmrc.gsi.gov.uk
If you have any doubt about the authenticity of an email you receive which claims to come from the Clearance and Counteraction Team, please call to check.
Information about market or price sensitive matters, or well known individuals, should not be sent by email.
If you email your application, please do not also send a hard copy.
Email the Clearance and Counteractions team
Before you fax any application to HMRC, please note the following:
General advice on specialist technical
areas of taxation
Statements of Practice and Extra
Statutory Concessions
Public
Notices for VAT, and Customs and Excise
Revenue and Customs Briefs - policy
changes resulting from legislation, litigation or policy reviews
Inheritance Tax clearance service for
business owners
