CIOT autumn conference

SPEAKERS

• Chris Whitehouse 5 Stone Buildings
• Peter Rayney Peter Rayney Tax Consulting Ltd
• Rebecca Benneyworth Rebecca Benneyworth & Co
• Anita Monteith ICAEW Tax Faculty

Pilot trusts: GAAR

Chris Whitehouse explained that the idea of setting up “pilot trusts” to give each discretionary settlement its own nil-rate band was specifically accepted as not abusive for the purposes of the general anti abuse rule (GAAR).

It is example D26 in the approved guidance and refers to FA 2013 s 207(5) which says that “the fact that tax arrangements accord with established practice and HMRC had … indicated its acceptance of that practice is an example of something which might indicate that the arrangements are not abusive”.

The failure of the Revenue to appeal the...