Guidance
GAAR Advisory Panel opinion of 12 April 2019: extraction of value using a second hand bond, gilt options, additional contributions and 'cooling off rights'
Use the GAAR Advisory Panel opinion on extraction of value using a second hand bond, gilt options, additional contributions and 'cooling off rights' 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 opinions cover:
- distribution
- loans or advances to participators
- arrangements conferring benefits on participators
- extraction of value by shareholders through joint acquisition by the company and its shareholders of a second hand bond
- the use of gilt options, additional contributions and ‘cooling off’ rights
They affect Income Tax 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