INTM180060 - Foreign entity classification for UK tax purposes: Contacts and clearances

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

Contacts and Clearances

We will provide our view of whether we consider a particular foreign entity to be transparent or opaque in specific cases in line with our guidance on non-statutory clearances at - http://www.gov.uk/guidance/non-statutory-clearance-service-guidance

Applications should be made in writing and include -

• the name and address of the entity to be considered
• why HMRC’s view is being requested
• consideration of factors 1 to 6 in INTM180020
• if a view is required in respect of a particular source of income, your view of how that source is taxed in the UK
• copies of any legislation, articles of association, by-laws, agreements or other documents governing the entity’s creation, continued existence and management, including any amending documents

Applications should be made by email to entityclassificationmailbox@hmrc.gov.uk or by post to:

HM Revenue and Customs
Business, Assets and International
Base Protection Policy Team
NE98 1ZZ

If you need HMRC’s view on whether particular entities constitute collective investment schemes, you should contact  cisc.sheffield@hmrc.gov.uk