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GAAR panel finding on corporation tax

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

Not so rewarding


  • 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...

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