GAAR Advisory Panel opinion of 28 February 2018: employee rewards using 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.
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Use this opinion together with the General Anti-Abuse Rule (GAAR) guidance to help you recognise abusive tax arrangements.
The opinion covers:
- employee benefits to employer-financed retirement benefit schemes (EFRBS)
- deeds of contribution
- employee loan agreements
- tripartite agreements
They affect Income Tax and Corporation Tax.
The GAAR Advisory Panel’s opinion is:
- entering into the tax arrangements isn’t a reasonable course of action in relation to the relevant tax provisions
- carrying out of the tax arrangements isn’t a reasonable course of action in relation to the relevant tax provisions