Section 703 - Make it clearer!

OVER THE LAST 18 months or so many tax practitioners have noticed a change in attitude at the Inland Revenue Clearance Unit with respect to clearance applications under TA 1988 s 707 (referred to in the rest of this article as s 703 ). The aim of this article is to highlight the issues perhaps to stimulate discussion within the profession and to establish a further dialogue with the Revenue in order to see if some of these issues can be resolved at least partly.

General observations

The Revenue's attitude towards s 703 particularly as it applies to the private equity field appears to have distinctly hardened over the last 18 to 24 months. This has manifested itself in a number of areas which are detailed later in the article. However my initial observations follow.

First there was an almost complete...