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.
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.
