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'

Use the GAAR Advisory Panel opinion on extraction of value using a second hand bond, gilt options, additional contributions and 'cooling off rights' to help you recognise abusive tax arrangements.

From:
HM Revenue & Customs
Published
20 May 2019

Documents

GAAR Advisory Panel opinion: extraction of value using a second hand bond, gilt options, additional contributions and 'cooling off rights' (company)

PDF, 663 KB, 9 pages

GAAR Advisory Panel opinion: extraction of value using a second hand bond, gilt options, additional contributions and 'cooling off rights' (Mr A)

PDF, 660 KB, 9 pages

GAAR Advisory Panel opinion: extraction of value using a second hand bond, gilt options, additional contributions and 'cooling off rights' (Mr B)

PDF, 661 KB, 9 pages

Details

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

The opinions cover:

  • distribution
  • loans or advances to participators
  • arrangements conferring benefits on participators
  • extraction of value by shareholders through joint acquisition by the company and its shareholders of a second hand bond
  • the use of gilt options, additional contributions and ‘cooling off’ rights

They affect Income Tax and Corporation Tax.

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 20 May 2019

Related content