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GAAR advisory panel publishes new opinion on EFRBS

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The GAAR advisory panel has published a third opinion concerning an employer-financed retirement benefit scheme (EFRBS). The panel reached the same conclusion as in its previous two opinions involving EFRBS, namely, that the entering into and carrying out of the arrangements was is not a reasonable course of action in relation to the relevant tax provisions.

The arrangements included a deed of contribution, employee loan agreement and tripartite agreement. The panel found that there was no economic difference between the arrangements in this case and a loan made to the employees by an employer-funded EFRB (see https://bit.ly/2v3R9CP).

The panel’s two earlier opinions involving EFRBS were issued on 26 January and 28 February 2018.

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