A form of application (with drafting notes) for clearance of a reconstruction under sections 138 and 139(5) of the Taxation of Chargeable Gains Act 1992 and section 831(2) of the Corporation Tax Act 2009. It should be read in conjunction with Practice notes, Schemes of reconstruction: tax and Tax clearances: exchange of securities and reconstructions.

The application caters for one transferor company and up to two transferee companies (in other words, a three-cornered demerger). For transactions involving different numbers of parties, the application should be adapted.