HMRC have published the GAAR Advisory Panel’s opinion on arrangements involving transfers of amounts into employee trusts (IHTA 1984 s 28) which sought to reduce or eliminate IHT.
The deceased had put around £1m into a company she had set up. The company established an employee trust and separately allocated shares to the deceased which were then gifted into the trust. The aim was that IHT on the deceased’s estate would be significantly reduced because of the effect of s 28.
Noting that the general intention behind the legislation was that family members should not benefit from the exemption and that considering the overall result of the arrangements the steps taken seemed ‘abnormal’ the Panel concluded that the entering into and carrying out of the tax arrangements were not reasonable courses of action.
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HMRC have published the GAAR Advisory Panel’s opinion on arrangements involving transfers of amounts into employee trusts (IHTA 1984 s 28) which sought to reduce or eliminate IHT.
The deceased had put around £1m into a company she had set up. The company established an employee trust and separately allocated shares to the deceased which were then gifted into the trust. The aim was that IHT on the deceased’s estate would be significantly reduced because of the effect of s 28.
Noting that the general intention behind the legislation was that family members should not benefit from the exemption and that considering the overall result of the arrangements the steps taken seemed ‘abnormal’ the Panel concluded that the entering into and carrying out of the tax arrangements were not reasonable courses of action.
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If you do not subscribe but are a registered user, please enter your details in the following boxes:
