GAAR Advisory Panel opinion of 30 June 2022: Extraction of cash (or equivalent) using trust interests, limited liability partnership and the novation of loans
Use the GAAR Advisory Panel opinion on the extraction of cash (or equivalent) using trust interests, limited liability partnership and the novation of loans, to help you recognise when arrangements may be abusive tax arrangements.
Documents
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 extraction of cash (or equivalent) using trust interests, limited liability partnership and the novation of loans.
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