TSEM1615 - Introduction to trusts: technical specialists in HMRC Trusts - submissions - authorisation, guidance and format
Authorisation
Income tax deeds examination submissions to HMRC Trusts & Estates Technical Edinburgh must be authorised by one of the 4 nominated deeds officers in HMRC Trusts & Estates offices.
All other submissions by HMRC Trusts & Estates offices to technical specialist must be authorised by a Grade 7 or the Compliance Manager as appropriate.
Guidance
There is general guidance on whether and how to make a submission in [(This text has been withheld because of exemptions in the Freedom of Information Act 2000)].
Format
Submissions to technical specialists in HMRC Trusts & Estates under TSEM1711 and TSEM2125
For requests under TSEM1711 or TSEM2125 where you need technical advice on the taxation of the trust, send a copy of the trust deed using deeds stencil 2 (Edinburgh) in the first instance. Also ensure that you
- quote the reference used by a technical specialist in any previous contact with your office
- flag relevant correspondence if there are more than a few items
- attach a tiger tag to the submission
- include other files that are relevant to the submission
If the case was selected by risk assessment give the reasons.
Other submissions to technical specialists in HMRC Trusts & Estates
For other submissions, follow (This text has been withheld because of exemptions in the Freedom of Information Act 2000) use the template provided adapted as follows:
- quote the reference used by a technical specialist in any previous contact with your office
- identify relevant instructions in the TSEM or other guidance manual
- draw attention to correspondence about the point at issue
- identify the tax at stake for all years, set out as follows:
-
- tax due according to your calculations
- tax due according to taxpayer’s or agent’s calculations
- difference
- if you are aware of other similar cases open for enquiry in your office or other HMRC Trusts & Estates offices, estimate number of cases and total tax at risk
- if you know of other trusts (including non-resident trusts) connected to the trust in question (same family or same company) that might feature the same issue, obtain and attach the relevant files
- flag relevant correspondence if there are more than a few items
- attach a tiger tag to the submission
- include other files that are relevant to the submission
- include a copy of the trust deed if relevant to the point at issue.
If the case was selected by risk assessment give the reasons.
Submissions that are not in this format may not be accepted. However a written memo instead of the template will be acceptable as long as you include all the information required, as detailed above.

