HM Revenue & Customs (HMRC) has issued a consultation document (Giving certainty to business through clearances and advance agreements: consultation document 20 June 2007) proposing to extend the circumstances in which advance clearance on the tax treatment of some transactions can be obtained. At present, non-statutory clearances are restricted to seeking clarification of the law contained in the last four Finance Acts. The new rules would remove the four-Finance-Act limit for clearance sought on transactions that are financially significant to the applicant business. In a related initiative, it is also proposed to set up a new unit to provide advance rulings in some high value cases of inward investment and reconstructions.
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