Guidance

GAAR Advisory Panel opinion of 17 November 2017: extraction of cash or equivalent through trust interests

Use the General Anti-Abuse Rule Advisory Panel opinion on distributions and benefits through trust interests to help you recognise abusive tax arrangements.

From:
HM Revenue & Customs
Published
11 December 2017

Documents

GAAR Advisory Panel opinion - extraction of cash through trust interests (company)

PDF, 355 KB, 10 pages

GAAR Advisory Panel opinion - extraction of cash through trust interests (Mr A)

PDF, 356 KB, 10 pages

Details

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

The opinions cover:

  • distributions
  • participator loans
  • participator benefits
  • extraction of cash (or equivalent) from close company through use of trusts and trust interests

They affect Income Tax and amounts chargeable as Corporation Tax.

The GAAR Advisory Panel’s opinion is:

  • entering into the tax arrangements isn’t a reasonable course of action in relation to the relevant tax provisions
  • carrying out of the tax arrangements isn’t a reasonable course of action in relation to the relevant tax provisions
Published 11 December 2017

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