Guidance

GAAR Advisory Panel opinion of 25 June 2018: employee rewards using deeds of contribution, employee loan and tripartite agreements

Use the GAAR Advisory Panel opinion on deeds of contribution, employee loans and tripartite agreements to help you recognise abusive tax arrangements.

From:
HM Revenue & Customs
Published
18 July 2018

Documents

GAAR Advisory Panel opinion of 25 June 2018: employee rewards using deeds of contribution, employee loan and tripartite agreements

PDF, 779 KB, 11 pages

Details

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

The opinion covers:

  • deeds of contribution
  • employee loan agreements
  • tripartite agreements
  • employee obligation to employer-financed retirement benefit schemes (EFRBS)

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

Updates to this page

Published 18 July 2018

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