Use the GAAR Advisory Panel opinion on the extraction of value from an estate, using options, by utilising property which is not excluded property, to help you recognise when arrangements may be abusive tax arrangements.
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Use the opinion together with the General Anti-Abuse Rule (GAAR) guidance to help you recognise when arrangements may be abusive tax arrangements.
This opinion covers the extraction of value from an estate, using options, by utilising property which is not excluded property for Inheritance Tax purposes.
The GAAR Advisory Panel opinion is that:
- entering into the tax arrangements is not a reasonable course of action in relation to the relevant tax provisions
- carrying out of the tax arrangements is not a reasonable course of action in relation to the relevant tax provisions
Published 11 April 2023
