Guidance

GAAR Advisory Panel opinion of 28 February 2018: employee rewards using contribution, employee loan and tripartite agreements

Use the GAAR Advisory Panel opinion on deeds of contribution, employee loans and tripartite agreements to help you recognise abusive tax arrangements.

From:
HM Revenue & Customs
Published
29 March 2018

Documents

GAAR Advisory Panel opinion of 28 February 2018: employee rewards using multiple deeds and tripartite agreements

PDF, 532 KB, 10 pages

Details

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

The opinion covers:

  • employee benefits to employer-financed retirement benefit schemes (EFRBS)
  • deeds of contribution
  • employee loan agreements
  • tripartite agreements

They affect Income Tax and 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 29 March 2018

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