What will HMRC consider reasonable rearranging of affairs where a clearance has been given under section 701 ITA 2007 (or section 707 Income and Corporation Taxes Act (ICTA) 1988)?
. A clearance under section 701 (or section 707) confirms that HMRC are satisfied that no counteraction should be taken under section 698 (or 703) about the transactions in securities that are described in the application for clearance. The provisions in Chapter 1 of Part 13 ITA 2007 are concerned with income tax but not capital gains tax (and since 6 April 2007 Chapter 1 of Part 17 ICTA 1988 is concerned only with Corporation Tax (CT)). No one is required to apply for clearance but we receive thousands of clearance applications each year from people who value the certainty it provides. The clearance we give relates only to the transactions described to us in the application. It is not possible to give a blanket statement of the view we will take where additional transactions not covered by the clearance are effected in order to take advantage of the current CGT rules. It will be a matter for judgement, in the light of the facts and circumstances of the particular case, whether the cle
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