Guidance

GAAR Advisory Panel opinion of 29 July 2026: Disguised Remuneration arrangements using dual payments (enablers of defeated tax avoidance)

Use the GAAR Advisory Panel opinion on Disguised Remuneration arrangements using dual payments to help you recognise when arrangements may be abusive tax arrangements.

• From: HM Revenue & Customs
• Published: 25 August 2026

Documents

Disguised Remuneration arrangements using dual payments — Company A

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Disguised Remuneration arrangements using dual payments — Company B

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Disguised Remuneration arrangements using dual payments — Company C

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Details

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

This opinion covers Disguised Remuneration arrangements using dual payments to help you recognise when arrangements may be abusive tax arrangements.

The GAAR Advisory Panel opinion is that:

• entering into the tax arrangements is not a reasonable course of action in relation to the relevant tax provisions
• carrying out of the tax arrangements is not a reasonable course of action in relation to the relevant tax provisions

Published 25 August 2026