Guidance

GAAR Advisory Panel opinion of 11 February 2022: Rewards via creation and sale of pension obligation

Use the GAAR Advisory Panel opinion on employee reward arrangements including creation and sale of pension obligations, to help you recognise abusive tax arrangements.

• From: HM Revenue & Customs
• Published: 6 May 2022
• Last updated: 10 March 2023 — See all updates

Documents

GAAR Advisory Panel opinion of 11 February 2022: Rewards via creation and sale of pension obligation

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Details

Use this opinion together with the General Anti-Abuse Rule (GAAR) guidance to help you recognise abusive tax arrangements.

This opinion covers employee reward arrangements including creation and sale of pension obligations.

The GAAR Advisory Panel’s opinion is:

• entering into the tax arrangements is not a reasonable course of action in relation to the relevant tax provisions

• carrying out the tax arrangements is not a reasonable course of action in relation to the relevant tax provisions

Published 6 May 2022
Last updated 10 March 2023 + show all updates

1. 10 March 2023

   The GAAR Advisory Panel opinion of 11 February 2022 has been updated with a date correction. The Opinion Notice was issued on 11 February 2022 and not on 14 February 2022.

2. 11 July 2022

   The GAAR Advisory Panel opinion of 11 February 2022 has been updated with changes to section 1, section 4.9 and minor changes throughout.

3. 6 May 2022

   First published.