Guidance

GAAR Advisory Panel opinion of 11 May 2021: Rewards in the form of loans for employees including contributions to a trust

Use the GAAR Advisory Panel opinion on employee reward arrangements including contributions to a trust, to help you recognise abusive tax arrangements.

• From: HM Revenue & Customs
• Published: 14 July 2021

Documents

GAAR Advisory Panel opinion of 11 May 2021: Rewards in the form of loans for employees including contributions to a trust - Company

ODT, 46.3 KB

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GAAR Advisory Panel opinion of 11 May 2021: Rewards in the form of loans for employees including contributions to a trust - Individual X

ODT, 48.8 KB

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GAAR Advisory Panel opinion of 11 May 2021: Rewards in the form of loans for employees including contributions to a trust - Individual Y

ODT, 48.4 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 abusive tax arrangements.

The opinion covers employee reward arrangements including contributions to a trust, a loan agreement under which the employee loans money to the manager of the trust and loans from the manager of the trust to the employee.

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

Published 14 July 2021