Guidance

GAAR Advisory Panel opinion of 16 December 2020: artificial repayment of a loan or advance to a participator

Use the GAAR Advisory Panel opinion on the artificial repayment of a loan or advance to a participator to help you recognise abusive tax arrangements.

• From: HM Revenue & Customs
• Published: 4 February 2021

Documents

GAAR Advisory Panel opinion of 16 December 2020: Artificial repayment of a loan or advance to a participator

ODT, 19.9 KB

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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 the artificial repayment of a loan or advance to a participator.

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 4 February 2021