HMRC delays in company reconstruction clearances

Many readers may be aware of major changes in HMRC’s clearance facility over the past couple of years. Initially these appeared to be purely administrative – on the retirement of the long-time head of the clearance team HMRC had decided to transfer the unit to Birmingham and recruited Birmingham-based staff into the team and appointed a new team leader. It is not clear whether the remaining members of the London-based team were offered the opportunity to relocate but it appears that none did. By about this time last year all the names familiar to those working in clearances had apparently been redeployed.

Clearly a mere change of personnel is not enough to warrant an article in Taxation but it has become apparent over the past 18 months or so that the new team is taking some positions that are very different from their...