Guidance

GAAR Advisory Panel opinion of 12 October 2018: employee rewards using loans

Use the GAAR Advisory Panel opinion on rewarding employees using loans, receiving their services through a third party, 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:

  • employee loan agreements
  • supply of employees’ services using a third party
  • 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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