Application for clearance s701 ITA 2007

Hello

We have a client who is a sole trader business who is selling up for cash and shares. We wish to treat the shares as capital rather than income. In order to do this, do we need to apply for clearance under s701 ITA 2007?

I believe this prevents a counteraction under s684 ITA 2007 .i.e HMRC cannot then come back and treat the shares as income

Can anyone clarify?

Thanks
anon

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Section 701 is not relevant ...

kenmoody |
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