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.
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Use this opinion together with the聽聽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