Guidance

GAAR Advisory Panel opinion of 29 October 2024: Reducing the value of an estate for Inheritance Tax and avoiding Inheritance Tax on a lifetime transfer by acquiring shares in a company and gifting those shares to an employee trust

Use the General Anti-Abuse Rule (GAAR) Advisory Panel opinion to help you recognise when arrangements may be abusive tax arrangements.

• From: HM Revenue & Customs
• Published: 18 February 2025

Documents

Reducing the value of an estate for Inheritance Tax (IHT) and avoiding IHT on a lifetime transfer by acquiring shares in a company and gifting those shares to an employee trust — PR1

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Reducing the value of an estate for Inheritance Tax (IHT) and avoiding IHT on a lifetime transfer by acquiring shares in a company and gifting those shares to an employee trust — PR2

ODT, 29.7 KB

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Reducing the value of an estate for Inheritance Tax (IHT) and avoiding IHT on a lifetime transfer by acquiring shares in a company and gifting those shares to an employee trust — trustee

ODT, 29.8 KB

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Details

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

This opinion covers the avoidance of Inheritance Tax by reducing the value of an estate for Inheritance Tax and avoiding Inheritance Tax on a lifetime transfer by acquiring shares in a company and gifting those shares to an employee trust.

The GAAR Advisory Panel opinion is that:

• entering into the tax arrangements is not a reasonable course of action in relation to the relevant tax provisions
• carrying out of the tax arrangements is not a reasonable course of action in relation to the relevant tax provisions

Published 18 February 2025