The general anti-abuse rule (“GAAR”) Advisory Panel recently published its opinion on rewards via the creation and sale of pension obligations.
The Panel’s opinion is that:-
- entering into the tax arrangements is not a reasonable course of action in relation to the relevant tax provisions; and
- carrying out the tax arrangements is not a reasonable course of action in relation to the relevant tax provisions.
An opinion has also been published on repayment of a participator's loan through transactions involving group companies and specifically when arrangements may not be abusive tax arrangements.