GAAR Advisory Panel opinion of 16 December 2020: artificial repayment of a loan or advance to a participator
Use the GAAR Advisory Panel opinion on the artificial repayment of a loan or advance to a participator to help you recognise abusive tax arrangements.
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Use this opinion together with the General Anti-Abuse Rule (GAAR) guidance to help you recognise abusive tax arrangements.
This opinion covers the artificial repayment of a loan or advance to a participator.
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