Abstract: . . .  characteristics of each case although certain information will be required in all cases (see below). 92. Clearance applications and questions regarding the clearance procedure should be sent to: HM Revenue & Customs Clearance & Counteraction Team, Anti Avoidance Group Intelligence First floor 22 Kingsway London WC2B 6NR Please mark the application “Capital losses clearance application”. Tel.: 020 7084 5525 Email: capitallosses.clearances@hmrc.gsi.gov.uk 93. A clearance will state the terms on which . . .
. . .  mean that all such arrangements between connected parties will be caught. Taxpayers should in such cases be guided by the information given in this document that the rules are targeted at arrangements where a main purpose was to secure a tax advantage through the use of capital losses in ways that reduce income profits. 76. For the purposes of section 184H, the definition of tax advantage in section 184D applies, but the tax advantage must also involve both the deduction of expenditure in calculating . . .
. . .  arrangements from which a tax advantage arises 5. Explanation of any commercial purpose for the arrangements Page 40 22 Part 7: Consultation This draft guidance is being published on 5 December 2005. The Government welcomes comments on this document and the draft clauses. Comments should be submitted by 5 February 2006. Please send your comments to: HM Revenue & Customs, CT & VAT Products and Processes 3rd Floor (Central) 100 Parliament Street London SW1A 2BQ Or email: robert.jordan@hmrc.gsi.gov.uk Telephone: . . .
. . .  losses had a significant effect on the terms and conditions of the acquisition. Page 23 5 Part 3: Restriction on a company's allowable losses 17. Amendments to section 8(2) TCGA 1992 and new legislation in subsections (2A) to (2C) focus on the contrived creation and realisation of capital losses. 18. There is evidence to show that a variety of schemes to generate capital losses which the existing legislation was never intended to produce are being marketed and implemented. Typically the schemes involve . . .
. . .  This draft guidance is being published on 5 December 2005. The Government welcomes comments on this document and the draft clauses. Comments should be submitted by 5 February 2006. Please send your comments to: HM Revenue & Customs, CT & VAT Products and Processes 3rd Floor (Central) 100 Parliament Street London SW1A 2BQ Or email: robert.jordan@hmrc.gsi.gov.uk Telephone: 020 7147 2622  . . .
. . .  which a tax advantage arises 5. Explanation of any commercial purpose for the arrangements Page 40 22 Part 7: Consultation This draft guidance is being published on 5 December 2005. The Government welcomes comments on this document and the draft clauses. Comments should be submitted by 5 February 2006. Please send your comments to: HM Revenue & Customs, CT & VAT Products and Processes 3rd Floor (Central) 100 Parliament Street London SW1A 2BQ Or email: robert.jordan@hmrc.gsi.gov.uk Telephone: 020 . . .
--3000,6,250,3326,81698