HMRC shines spotlight on avoidance scheme

HMRC’s spotlight 56 highlights the arrangements considered recently by the GAAR panel, where a company rewarded its director using loans made through an offshore remuneration trust. HMRC’s guidance highlights actions HMRC may take in relation to the use of similar arrangements without going back to the GAAR panel for a new opinion, including issuing a counteraction notice and also an accelerated payment notice to require upfront payment of the disputed tax.