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The General Anti-Abuse Rule (GAAR) Advisory Panel has published details of three opinions covering employee rewards that use loans which found that the planning used was unreasonable.

The 11 May 2021 opinions outlined the employee arrangements:

HMRC contended that:

The taxpayer contended that:

The GAAR Panel concluded that neither entering into nor carrying out the arrangements was a reasonable course of action as:

Useful guides on this topic

General Anti-Abuse Rule (GAAR) (subscriber)
This guide looks at the key features of the General Anti-Abuse Rule (GAAR) contained within the Finance Act 2013, what areas of tax it covers and what you need to know about the provisions it contains when considering tax planning.

General Anti-Abuse Rule: GAAR at a glance (freeview)
This note looks at the key features of the General Anti-Abuse Rule (GAAR) contained within the Finance Act 2013 and the basics of what you need to know about the provisions it contains when considering tax planning.

Disguised remuneration loan charge
What is disguised remuneration? What is the loan charge? When does the loan charge apply? Will the loan charge affect me?

Disguised remuneration: At a glance (freeview)
At a glance freeview introduction to the Disguised Remuneration rules.

Directors' loan accounts: Toolkit (subscribers)
HM Revenue & Customs (HMRC) do a toolkit for advisers. This is our enhanced version with planning points. 

Directors' loan accounts: Toolkit (freeview)
This is a freeview 'At a glance' version of HMRC's Directors' loan accounts toolkit for advisers with planning points.

External links

GAAR Advisory Panel opinion of 11 May 2021: Rewards in the form of loans for employees including contributions to a trust

 


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