Guidance

GAAR Advisory Panel opinion of 30 January 2026: reducing the value on an estate for Inheritance Tax and avoiding Inheritance Tax on a lifetime transfer by gifting shares held in an existing company to an employee trust

Use the General Anti-Abuse Rule (GAAR) Advisory Panel opinion to help you recognise when arrangements may be abusive tax arrangements.

• From: HM Revenue & Customs
• Published: 12 May 2026

Documents

Reducing the value of an estate for Inheritance Tax and avoiding Inheritance Tax on a lifetime transfer by gifting shares held in an existing company to an employee trust — PR1

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Reducing the value of an estate for Inheritance Tax and avoiding Inheritance Tax on a lifetime transfer by gifting shares held in an existing company to an employee trust — PR2

ODT, 31.8 KB

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Reducing the value of an estate for Inheritance Tax and avoiding Inheritance Tax on a lifetime transfer by gifting shares held in an existing company to an employee trust — PR3

ODT, 36.8 KB

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Reducing the value of an estate for Inheritance Tax and avoiding Inheritance Tax on a lifetime transfer by gifting shares held in an existing company to an employee trust — trustee

ODT, 33 KB

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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 the avoidance of Inheritance Tax, by gifting shares held in an existing company to an employee trust to:

• avoid Inheritance Tax on a lifetime transfer
• reduce the value of an estate for Inheritance Tax

The GAAR Advisory Panel’s 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 12 May 2026