Corporation Tax Act 2009 section 678

Procedure on application for clearance

Section 678 sets out the procedure a company must follow when applying to HMRC for clearance that the tax avoidance provisions of section 677 should not apply to a European cross-border transfer of business involving derivative contracts.

• The application must be made in writing and include full details of the planned operations
• HMRC may request further particulars within 30 days of receiving the application or any previously requested information
• The applicant must supply the requested information within 30 days, unless HMRC allows a longer period
• If the applicant fails to provide the requested information within the permitted time, HMRC may decline to process the application further