CTM00505 - Introduction: preface

Giving advice to companies

HMRC Code of Practice 10 - ’information and advice' - sets out the various ways in which HMRC aims to achieve its policy of helping taxpayers.

These include:

• providing general advice,
• giving 'post-transaction rulings’,
• providing our interpretation of tax law in some circumstances,
• giving statutory clearances and approvals for certain types of transactions.

Uniformity of treatment

The instructions provide for uniformity of treatment between all taxpayers. However, a novel situation may arise or a new interpretation of the law or practice may seem appropriate to a matter which could become publicly sensitive. For example, an officer may wish to apply his decision to a whole class of taxpayers or a trade. In these circumstances he should consult the appropriate specialist before taking up the matter with the company or its advisers.

Cases where very substantial amount of tax in issue

It is essential that the Board's freedom to act is not restricted by the premature agreement of liability where a very substantial amount of tax is in issue. The guidance at BIM00530 sets out the procedure for reporting such cases.

United Kingdom

The expression 'United Kingdom' means Great Britain and Northern Ireland. It does not include the Irish Republic, the Isle of Man or the Channel Islands.