Mark McLaughlin looks at taxpayer clearance applications to HM Revenue and Customs and whether clearances given can be relied upon.
Whilst death and taxes are said to be the only certainties in life, certainty is often conspicuously absent when seeking to establish the tax treatment of an event or transaction.
HM Revenue and Customs (HMRC) recognises the need for taxpayers and advisers to have certainty, or at least a statement of HMRC’s view, on important tax issues. Consequently, HMRC has published a plethora of information on the Gov.uk website.
For example, probably the most useful guidance for tax advisers is published in HMRC’s manuals (www.gov.uk/government/collections/hmrc-manuals), which contain technical