Someone owns two companies, both newly incorporated and neither have received income yet. Wished for one of the companies to become subsidiary of the other via share for share exchange.
Given that these companies effectively have no value aside from the nominal share amounts, is clearance from HMRC required?
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Clearance is never required as such. It's just that, if you get it, you at least have some assurance about the tax outcome.
I agree. The question should be is clearance necessary, to which the answer is no, because there are no adverse tax consequences if the effects of a clearance are not obtained.
That is, of course, based on the shares in the would be subsidiary company having no value.
