Flotations — HMRC clearances | Tax Guidance

Flotations — HMRC clearances

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Corporation Tax

Guidance

Various tax clearances are generally applied for as part of (and prior to) flotation of a company including:

•
TCGA 1992, s 138 clearance to confirm share for share exchange relief on a reorganisation / reconstruction in preparation for the flotation (see the Paper for paper treatment clearances guidance note)
•
ITA 2007, s 701, and

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Anne Fairpo

Barrister

With effect from 1 June 2021, Anne Fairpo is a judge of the First-tier Tribunal sitting in the Tax Chamber. She was previously a fee-paid judge in the same Chamber. Her contributions to LexisPSL Tax and TolleyGuidance were written before her full-time appointment and are her personal view as she is not authorised to write on behalf of the Tribunals Service or the judiciary. Until April 2021, Anne was a tenant at Temple Tax Chambers. She was called to the bar in 2009 after 15 years as a solicitor. Anne’s experience and expertise covers UK and international corporate tax planning and disputes, having acted for a range of clients from small owner-managed businesses to listed multinationals, as well as having advised on intellectual property taxation and UK-US cross-border tax planning, with regard to both direct and indirect tax matters

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