Collection

Tax avoidance: General Anti-Abuse Rule

Use the General Anti-Abuse Rule (GAAR) guidance and Advisory Panel opinions to help you recognise tax avoidance schemes.

• From: HM Revenue & Customs
• Published: 3 August 2017
• Last updated: 15 May 2024
  Show all updates

  1. 15 May 2024

     In the General Anti-Abuse Rule (GAAR) Advisory Panel Opinions section, we have made it clear that we will only publish opinions if they can be anonymised.

  2. 11 February 2021

     The latest GAAR Panel opinion of 16 December 2020 has been added.

  3. 8 October 2019

     The latest GAAR Panel opinion of 7 August 2019 has been added.

  4. 25 February 2019

     The latest GAAR Panel opinion of 25 January 2019 has been added.

  5. 31 July 2018

     GAAR factsheets have been added to the collection.

  6. 3 August 2017

     First published.

GAAR guidance

Use the GAAR guidance to help you recognise abusive tax arrangements.

• Tax avoidance: general anti-abuse rule guidance - latest version
  • 16 July 2021
  • Guidance
• Tax avoidance: general anti-abuse rule guidance - earlier versions
  • 16 July 2021
  • Guidance

GAAR Advisory Panel opinions

Use these opinions and the GAAR guidance to help you recognise abusive tax arrangements. We will only publish an opinion here if we can anonymise it to protect taxpayer confidentiality.

Read more about the GAAR Advisory Panel.

• GAAR Advisory Panel opinion of 29 July 2026: Disguised Remuneration arrangements using dual payments (enablers of defeated tax avoidance)
  • 25 August 2026
  • Guidance
• GAAR Advisory Panel opinion of 30 January 2026: reducing the value of an estate for Inheritance Tax and avoiding Inheritance Tax on a lifetime transfer by gifting shares held in an existing company to an employee trust
  • 22 July 2026
  • Guidance
• GAAR Advisory Panel opinion of 30 January 2026: reducing the value of an estate for Inheritance Tax and avoiding Inheritance Tax on a lifetime transfer by acquiring shares in a company and gifting those shares to an employee trust
  • 22 July 2026
  • Guidance
• GAAR Advisory Panel opinion of 29 October 2024: Reducing the value of an estate for Inheritance Tax and avoiding Inheritance Tax on a lifetime transfer by acquiring shares in a company and gifting those shares to an employee trust
  • 18 February 2025
  • Guidance
• GAAR Advisory Panel opinion of 29 October 2024: Reward through creation of an obligation to make pension payments to employees and the transfer of that obligation to another employee in exchange for payment
  • 17 February 2025
  • Guidance
• GAAR Advisory Panel opinion of 7 August 2024: Reward through creation and sale of a pension obligation with consideration paid to the owner of the pension obligation
  • 18 October 2024
  • Guidance
• GAAR Advisory Panel opinion of 20 January 2023: Stamp Duty Land Tax arrangements in relation to the sale and purchase of a residential property that involve a sub-sale and an annuity (enablers of defeated tax avoidance)
  • 11 April 2023
  • Guidance
• GAAR Advisory Panel opinion of 13 January 2023: Extraction of value from an estate, using options, by utilising property which is not excluded property for Inheritance Tax purposes
  • 11 April 2023
  • Guidance
• GAAR Advisory Panel opinion of 15 September 2022: Unauthorised payment from registered pension scheme involving debt arrangement
  • 2 December 2022
  • Guidance
• GAAR Advisory Panel opinion of 27 July 2022: Stamp Duty Land Tax arrangements in relation to the sale and purchase of a residential property, involving an alternative finance agreement and a lease agreement (enablers of defeated tax avoidance)
  • 5 October 2022
  • Guidance
• GAAR Advisory Panel opinion of 30 June 2022: Extraction of cash (or equivalent) using trust interests, limited liability partnership and the novation of loans
  • 28 September 2022
  • Guidance
• GAAR Advisory Panel opinion of 26 April 2022: Repayment of a participator loan through transactions involving group companies
  • 21 July 2022
  • Guidance
• GAAR Advisory Panel opinion of 11 February 2022: Rewards via creation and sale of pension obligation
  • 10 March 2023
  • Guidance
• GAAR Advisory Panel opinion of 11 May 2021: Rewards in the form of loans for employees including contributions to a trust
  • 14 July 2021
  • Guidance
• GAAR Advisory Panel opinion of 16 December 2020: artificial repayment of a loan or advance to a participator
  • 4 February 2021
  • Guidance
• GAAR Advisory Panel opinion of 7 April 2020: Rewards in the form of loans for employees including contributions to a trust
  • 28 August 2020
  • Guidance
• GAAR Advisory Panel opinion of 2 March 2020: Reducing an estate's value for inheritance tax via subscription for shares in a new company and gifting shares to an employee succession trust
  • 6 May 2020
  • Guidance
• GAAR Advisory Panel opinion of 12 February 2020: miscellaneous income losses
  • 16 March 2020
  • Guidance
• GAAR Advisory Panel opinion of 7 August 2019: extraction of value from a company by its directors and shareholders
  • 8 October 2019
  • Guidance
• GAAR Advisory Panel opinion of 12 April 2019: extraction of value using a second hand bond, gilt options, additional contributions and 'cooling off rights'
  • 20 May 2019
  • Guidance
• GAAR Advisory Panel opinion of 28 May 2019: extraction of value using a second hand bond, gilt options, additional contributions and 'cooling off rights'
  • 2 July 2019
  • Guidance
• GAAR Advisory Panel opinion of 11 April 2019: employee rewards using a second hand bond, gilt options, additional contributions and 'cooling off rights'
  • 20 May 2019
  • Guidance
• GAAR Advisory Panel opinion of 25 January 2019: Individuals claiming relief for film related losses and split sale of interest in partnership
  • 22 February 2019
  • Guidance
• GAAR Advisory Panel opinion of 12 October 2018: employee rewards using loans
  • 7 November 2018
  • Guidance
• GAAR Advisory Panel opinion of 11 October 2018: contractor rewards using loans
  • 7 November 2018
  • Guidance
• GAAR Advisory Panel opinion of 25 June 2018: employee rewards using deeds of contribution, employee loan and tripartite agreements
  • 18 July 2018
  • Guidance
• GAAR Advisory Panel opinion of 28 February 2018: employee rewards using contribution, employee loan and tripartite agreements
  • 29 March 2018
  • Guidance
• GAAR Advisory Panel opinion of 26 January 2018: employee rewards using multiple tripartite arrangements
  • 26 February 2018
  • Guidance
• GAAR Advisory Panel opinion of 17 November 2017: extraction of cash or equivalent through trust interests
  • 11 December 2017
  • Guidance
• GAAR Advisory Panel opinion of 10 November 2017: employee rewards using gold bullion
  • 11 December 2017
  • Guidance
• GAAR Advisory Panel opinion of 9 November 2017: employee rewards using gold bullion
  • 11 December 2017
  • Guidance
• GAAR Advisory Panel opinion of 18 July 2017: employee rewards using gold bullion
  • 3 August 2017
  • Guidance

GAAR factsheets

HMRC will send you a factsheet when you’ve used tax arrangements that the GAAR may apply to.

• Compliance checks: information about the general anti-abuse rule — CC/FS34a
  • 29 September 2022
  • Guidance
• General anti-abuse rule and pooling notices – CC/FS35
  • 29 September 2022
  • Guidance
• Compliance checks: provisional counteraction notices given under the GAAR — CC/FS36
  • 26 March 2018
  • Guidance
• Compliance checks: protective GAAR notices – CC/FS36a
  • 31 May 2022
  • Guidance
• Compliance checks: General anti-abuse rule and notices of binding — CC/FS37
  • 26 August 2022
  • Guidance