Guidance

GAAR Advisory Panel opinion of 30 June 2022: Extraction of cash (or equivalent) using trust interests, limited liability partnership and the novation of loans

Use the GAAR Advisory Panel opinion on the extraction of cash (or equivalent) using trust interests, limited liability partnership and the novation of loans, to help you recognise when arrangements may be abusive tax arrangements.

From:
HM Revenue & Customs
Published
28 September 2022

Documents

Extraction of cash (or equivalent) using trust interests, limited liability partnership and the novation of loans — company

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Extraction of cash (or equivalent) using trust interests, limited liability partnership and the novation of loans — individual

ODT, 23.2 KB

This file is in an OpenDocument format

This file may not be suitable for users of assistive technology.

Request an accessible format.
If you use assistive technology (such as a screen reader) and need a version of this document in a more accessible format, please email different.format@hmrc.gov.uk. Please tell us what format you need. It will help us if you say what assistive technology you use.

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 extraction of cash (or equivalent) using trust interests, limited liability partnership and the novation of loans.

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 28 September 2022

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