Guidance

GAAR Advisory Panel opinion of 11 April 2019: employee rewards using a second hand bond, gilt options, additional contributions and 'cooling off rights'

Use the GAAR Advisory Panel opinion on employee rewards using a second hand bond, gilt options, additional contributions and 'cooling off rights' to help you recognise abusive tax arrangements.

From:
HM Revenue & Customs
Published
20 May 2019

Documents

GAAR Advisory Panel opinion: employee rewards using a second hand bond, gilt options, additional contributions and 'cooling off rights' (company)

PDF, 493 KB, 16 pages

GAAR Advisory Panel opinion: employee rewards using a second hand bond, gilt options, additional contributions and 'cooling off rights' (individual)

PDF, 447 KB, 14 pages

Details

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

The opinions cover:

  • disguised remuneration
  • rewards passed to employees and shareholders through joint acquisition by the company and employees of a second hand bond
  • the use of gilt options, additional contributions and ‘cooling off’ rights

They affect Income Tax and National Insurance contributions.

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 20 May 2019

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