Guidance

GAAR Advisory Panel opinion of 26 April 2022: Repayment of a participator loan through transactions involving group companies

Use the GAAR Advisory Panel opinion on a repayment of a participator loan through transactions involving group companies, to help you recognise when arrangements may not be abusive tax arrangements.

• From: HM Revenue & Customs
• Published: 21 July 2022

Documents

Repayment of a participator loan through transactions involving group companies

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Details

Use this opinion together with the General Anti-Abuse Rule (GAAR) guidance to help you recognise when arrangements may not be abusive tax arrangements.

This opinion covers the repayment of a participator loan through transactions involving group companies.

The GAAR Advisory Panel’s opinion is:

• entering into the tax arrangements was a reasonable course of action in relation to the relevant tax provisions
• carrying out the tax arrangements was a reasonable course of action in relation to the relevant tax provisions

Published 21 July 2022