HM Revenue and Customs Brief 20/08
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Issued 1 April 2008
Extension of non-statutory clearances service for HM Revenue and Customs
(HMRC) business customers
Who should read this business brief?
All businesses and those acting on behalf of business.
At Budget 2006, the Chancellor of the Exchequer announced a review, led by
Sir David Varney, of the relationship between large business and HMRC.
The review team consulted with over 140 large businesses and trade and
representative bodies and identified four key outcomes that would benefit both
large business and HMRC:
- greater certainty
- an efficient risk based approach to dealing with tax matters
- speedy resolution of issues
- clarity through effective consultation and dialogue
The ‘Review of Links with Large Business’ report published in November 2006
outlined 14 key proposals that would together deliver these outcomes.
One of the proposals related to non-statutory clearances. A non-statutory
clearance is written confirmation of our view of the application of tax law to a
specific transaction or event.
At Pre-Budget Report 2007, we announced an extension of the non-statutory
clearances we provide to all our business customers from April 2008.
Changes affecting business
From 1 April 2008 clearances will be provided across all business taxes
regardless of the age of the legislation, where there is material uncertainty.
For direct tax legislation older than the last four Finance Acts, there is a
further requirement that the uncertainty relates to a commercially significant
We will aim to respond to clearance applications within 28 calendar days,
though in complex cases this may take longer.
In addition, as part of the extended clearances service from 1 April 2008, we
will publish new guidance on clearances for our business customers, bringing
together and updating existing guidance so as to provide a consistent and clear
framework for clearance applications across HMRC. The guidance for businesses is
available on the HMRC website.
Who do I contact?
Large Business Service (LBS) customers should continue to send their
clearance applications to their Client Relationship Manager (CRM).
All other business customers, and those acting on behalf of a business,
should send their applications to:
HMRC Clearances Team
21 Victoria Avenue
Essex SS99 1BD
Email: HMRC Clearances
Comments on the guidance and the extended service can be sent to:
Tax Administration Policy
100 Parliament Street
Other guidance on information and advice
Code of Practice 10 (COP10) and Notice 700/6 VAT rulings will remain in place
for our customers who are not covered by the new clearances process to provide
guidance on how to seek information and advice from HMRC. We will be reviewing
these documents over the next year to provide more consistent guidance on the
information and advice available to our customers.
About the Author
© Crown Copyright 2008.
A licence is need to reproduce this article and has been republished for
educational / informational purposes only. Article reproduced by permission of
HM Revenue & Customs under the terms of a Click-Use Licence. Tax briefs are
updated regularly and may be out of date at time of reading.
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Article Published/Sorted/Amended on Scopulus 2008-04-02 16:07:55 in Tax Articles