2452.This section is based on section 776(11) of ICTA; apart from differences of the kind described in the Overview, it replicates exactly section 770 of ITA.
2453.This section includes a minor change in the law. Section 776(11) of ICTA gives the clearance function to “the inspector to whom [the taxpayer] makes its return of income”. In practice, HMRC do not interpret this restrictively. This section gives the clearance function to the Commissioners for HMRC. See Change 53 in Annex 1, which corresponds to Change 118 in Annex 1 to the explanatory notes on ITA.