Senior corporate figures are concerned that a new procedure could mean companies will have to confirm clearance to please investors before flotations, M&A deals and other capital raisings.

The fears have been raised at high-level meetings of business figures and HMRC chiefs, with the group ­ the Business Tax Forum ­ set to lock horns on the issue again on Monday of next week.

Businesses are fretting that major corporate transactions could require the blessing of HMRC to go ahead under the taxman’s plans to provide clearances on complex tax arrangements.

‘When dealing in funds with the public, the prospectus would need to contain HMRC clearance on the tax implications for the fund to be marketable. Clearances may become market practice. If one business applies their competitors will be obliged to follow,’ business representatives said in minutes from the September 2007 meeting, which were released by HMRC last week.

The possibility of such a scenario has raised concerns among tax lawyers and advisers who are worried that they may come under commercial pressure to obtain clearances for indemnity purposes.

HMRC, meanwhile, is equally concerned it will be deluged with clearance applications, even for straightforward transactions, as advisers seek to cover themselves.

‘This is one of the worries with a clearance system. When you have a complex tax system, there are grey areas, so where clearance is available a business is going to go for it,’ said Michael Templeman of Schroders, who sits on the Business Tax Forum.

Obtaining clearance from government agencies for corporate transactions has been an ongoing issue for other state bodies.

The Pensions Regulator has become increasingly powerful over the past two years after it was given retrospective powers to force companies to pump cash into the pension schemes of an acquired business if it felt that pension funds were underfunded.

The regulator offered business a voluntary clearance process for pension funding arrangements, but the threat of facing a contribution notice later on has meant that many companies have opted to apply for clearance if though they don't have to.

Dealmakers have accused the regulator of delaying deals through the clearance process and holding too much influence over transactions. This has raised the possibility of similar disputes erupting over HMRC clearances.

HMRC said it would update guidance on clearances continuously.