Guidance

GAAR Advisory Panel opinion of 11 October 2018: contractor rewards using loans

Use the GAAR Advisory Panel opinion on contractor rewards using loans and transfer of creditor rights to Employer Financed Retirement Benefit Schemes, to help you recognise abusive tax arrangements.

Documents

Details

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

The opinion covers:

  • contractor loan agreements
  • transfer of creditor rights to employer-financed retirement benefit schemes (EFRBS)

It affects Income Tax, National Insurance contributions and Corporation Tax.

The GAAR Advisory Panel’s opinion is:

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

Updates to this page

Published 7 November 2018

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