CG44150 - Targeted rules to prevent income to capital converter schemes by companies - informal clearances
Companies and their representatives may make requests for advice about the legislation in TCGA92/S184G to H, including whether the provisions will apply to a planned series of transactions that may constitute an arrangement.
It is important that any request for advice is made on the basis of full disclosure of all relevant facts, in order that any advice given may be relied upon.
HMRC will give advice concerning actual or proposed transactions. Where possible, we will confirm that no notice will be issued in respect of the disclosed transactions. If the information disclosed is insufficient to enable us to reach a decision, we will say so and if possible indicate what further information should be provided.