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GAAR advisory panel issues two new opinions

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The GAAR advisory panel has issued two new opinions, each involving a form of contractor loan scheme and transfer of creditor rights to an employer financed retirement benefit scheme (EFRBS). In each case, the panel’s conclusion was that the entering into and carrying out of the arrangements was not a reasonable course of action in relation to the relevant tax provisions.

  • Opinion of 11 October 2018: contractor rewards using loans, involved a contractor loan scheme involving transfer of creditor rights to an EFRBS (
  • Opinion of 12 October 2018: employee rewards using loans, involved arrangements designed to reward an employee by receiving his services through a third party, augmented by loans with creditor rights transferred to an EFRBS (