HMRC has issued a new
version of the GAAR guidance, to apply from 11 September 2020. The main
change is to the procedural guidance in Part E (at section 3.7A) to add
information on the protective GAAR notice. A protective GAAR notice is a notice
stating that HMRC considers that a tax advantage might have arisen to a person
from tax arrangements that are abusive, and that if there is a tax advantage,
it ought to be counteracted under the GAAR.
HMRC has made the previous
versions of the GAAR guidance available separately, and notes that the
version of the guidance that was published at the time the arrangements were
entered into is the correct version that should be used.
HMRC has issued a new
version of the GAAR guidance, to apply from 11 September 2020. The main
change is to the procedural guidance in Part E (at section 3.7A) to add
information on the protective GAAR notice. A protective GAAR notice is a notice
stating that HMRC considers that a tax advantage might have arisen to a person
from tax arrangements that are abusive, and that if there is a tax advantage,
it ought to be counteracted under the GAAR.
HMRC has made the previous
versions of the GAAR guidance available separately, and notes that the
version of the guidance that was published at the time the arrangements were
entered into is the correct version that should be used.
