Government consultation document: "A General Anti-Abuse Rule". The response covers our views and concerns in relation to:
- The scope of the general anti-abuse rule (GAAR).
- The lack of certainty offered by the GAAR.
- The role of the GAAR Advisory Panel as a "taxpayer safeguard".
- How HMRC will determine whether the obtaining of a tax advantage was the main purpose or one of the main purposes of arrangements entered into by the taxpayer.
- Whether and how the GAAR will apply to existing tax avoidance strategies, particularly in relation to inheritance tax mitigation.
- How the GAAR will interact with existing targeted anti-avoidance rules (TAARs) and other tax legislation.
- The over-reliance on HMRC guidance which is not legally binding rather than providing clear legislation for the GAAR.
- International double taxation arrangements which will be overridden by the proposed GAAR.
To read our full consultation response, please click below." />
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