Guidance

GAAR Advisory Panel opinion of 7 August 2024: Reward through creation and sale of a pension obligation with consideration paid to the owner of the pension obligation

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 October 2024

Documents

Reward through creation and sale of a pension obligation with consideration paid to the owner of the pension obligation

ODT, 61.6 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 employee reward arrangements involving the creation and sale of a pension obligation with the consideration paid to the owner of the pension obligation

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 October 2024