CTM00505 - Introduction: preface

Giving advice to companies

HMRC will confirm its view of the tax treatment of transactions where there is genuine uncertainty about how the rules apply. »Ê¹ÚÌåÓýapp current procedure for obtaining non-statutory clearances is at

/guidance/non-statutory-clearance-service-guidance

Clearances generally are dealt with at

/guidance/seeking-clearance-or-approval-for-a-transaction

Uniformity of treatment

»Ê¹ÚÌåÓýapp guidance provides 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 a decision to a whole class of taxpayers or a trade. (This content has been withheld because of exemptions in the Freedom of Information Act 2000) .

Cases where very substantial amount of tax in issue

It is essential that the Commissioners� freedom to act is not restricted by the premature agreement of liability where a very substantial amount of tax is in issue. (This content has been withheld because of exemptions in the Freedom of Information Act 2000) .

United Kingdom

»Ê¹ÚÌåÓýapp expression ‘United Kingdomâ€� means Great Britain and Northern Ireland. It does not include the Irish Republic, the Isle of Man or the Channel Islands.