Taxation logo taxation mission text

Since 1927 the leading authority on tax law, practice and administration

GAAR panel finding on corporation tax

10 October 2017 / Pam Keogh
Issue: 4619 / Categories: Comment & Analysis

Not so rewarding

KEY POINTS

  • Corporation tax deduction on company expenditure.
  • Requirement for a corresponding PAYE and National Insurance charge.
  • Impact of the panel’s opinion on other tax planning.

Only in July the general anti-abuse rule (GAAR) advisory panel delivered a blow to arrangements between a company its employees and an employee benefit trust (EBT) using gold bullion.

I will focus only on the corporation tax issues of the panel’s opinion because Andrew Hubbard has already covered the PAYE National Insurance and ITEPA 2003 Pt 7A aspects in 
his article ‘Start of something big’ (Taxation 17 August 2017).

In brief the facts were:

  • two employees together owned 100% of a company of which they were also directors;
  • the company funded the purchase of gold...

If you or your firm subscribes to Taxation.co.uk, please click the login box below:

If you are not a subscriber but are a registered user or have a free trial, please enter your details in the following boxes:

Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this item in full.

Please reach out to customer services at +44 (0) 330 161 1234 or 'customer.services@lexisnexis.co.uk' for further assistance.

back to top icon