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Are HMRC seeking to influence the structure of business deals?
KEY POINTS
- Statutory and non-statutory clearances can give rise to unexpected challenges from HMRC.
- Is the main purpose of the transaction commercial or to obtain a tax advantage?
- A clearance applicant can require HMRC to refer to the tribunal.
- Evidence to support the transaction could prove crucial.
Dealing with HMRC might at times seem analogous to footballers who had differences of opinion with Brian Clough.
An interviewer once asked him “How do you react when someone from your playing staff comes and says ‘Boss I think you’re doing this wrongly’?”
He replied: “I ask him which way he thinks it should be done. We get down to it and then we talk about it for 20 minutes and then we decide I was right.”
Tax is so riddled with uncertainties...
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