INTM596570 - Arbitrage: legislation and principles: procedures: Format of clearance application: receipts
HMRC would expect to receive the following basic information in a clearance application:
Receipts
A Details of scheme participants
-
Company
- Name of company (and details of any branches including those in the UK)
- Name of ultimate UK parent (if member of a group)
- Nature of the business of company
- Territory of residence
- UK Tax office and reference number
- Connection (if any) to paying party and other participants
-
Copy of most recent accounts
-
Paying party
- Name of company (and details of any branches including those in the UK)
- Name of ultimate UK parent (if member of a group)
- Nature of the business of company
- Territory of residence
- UK Tax office and reference number (where applicable)
-
Connection (if any) to company and other participants
-
Other participants
- Name of each company (and details of any branches including those in the UK)
- Name of ultimate UK parent of each company (if member of a group)
- Nature of the business of each company
- Territory of residence of each company
- UK Tax office and reference number of each company (where applicable)
- Connection (if any) to other participants
B Details of the scheme
- Description of the proposed scheme
- Nature and amount(s) of all relevant transaction(s)
- Details of the tax deduction(s) (or other relief(s)/allowance(s)) available to the paying party and the territory in which each is available
- Explanation as to why the payment is not brought into account under FA96/S91A
- Explanation as to why the payment is not otherwise brought into account as income or gains.