SP02/07 - Support for Inward Investment and Corporate Reconstruction

This Statement of Practice provides advice on the support that HMRC will give to inward investors and businesses involved in corporate reconstructions.

Support for inward investments

The Advance Agreements Unit (AAU) provides a range of services to businesses involved in significant inward investments. For these purposes significant inward investments are regarded as inward investments amounting to £250 million or more in value. However support will also be provided when HMRC agrees with the applicant that an inward investment below that figure is of importance to the national or regional economy or in the wider public interest.

Services include:

• Rulings which business can rely on consistent with administrative law across all taxes where there is uncertainty about the application of the existing law to the specific transaction;
• A “one stop shop” which co-ordinates responses from different parts of HMRC depending on the taxes and duties involved;
• A fast track towards an agreement where time is of the essence;
• Help for inward investors who seek advice on HMRC’s taxes and systems.

As well as these services for significant inward investments, the AAU will help all inward investors who need advice on whom to contact within HMRC. It will also provide advice on HMRC products and processes to organisations promoting inward investment into the UK.

Businesses or their agents should contact the AAU on telephone number 020 7147 3345 or email advanceagreementsunit.CT&VAT@hmrc.gsi.gov.uk. The unit will agree with them a timetable for providing an advance agreement and the information that will be required. Information that businesses will be asked to provide will include details of the business and the proposed inward investment and an explanation of the areas of uncertainty about the application of the law on which an agreement is being sought. Where appropriate, businesses will be asked to provide a summary of the relevant alternative interpretations of the legislation that they have already considered to illustrate the point of uncertainty.