Guidance

GAAR Advisory Panel opinion of 29 October 2024: Reward through creation of an obligation to make pension payments to employees and the transfer of that obligation to another employee in exchange for payment

Use the GAAR Advisory Panel opinion to help you recognise when arrangements may be abusive tax arrangements.

• From: HM Revenue & Customs
• Published: 17 February 2025

Documents

Reward through creation of an obligation to make pension payments to employees, the transfer of those obligations to another employee and the payment for taking on each obligation being discharged by payment to the other employee

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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 employee reward arrangements involving the creation and subsequent sale of pension obligations to another employee with the consideration for taking on each obligation being discharged by payment to the other employee.

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 17 February 2025