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