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GAAR and notices of binding

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HMRC has updated its factsheet CC/FS37: Compliance checks: general anti-abuse rule and notices of binding on notices of binding and bound arrangements opinion notices under the general anti-abuse rule (GAAR), particularly to cover the deadline by which corrective action should be taken and the subsequent ‘closed period’ during which no GAAR-related adjustments may be made.

Changes have been made to reflect clarifications to the meaning of ‘closed period’ in FA 2013 s 209 (as introduced by FA 2021 Sch 32 para 3). A new section ‘closed period’ covers the deadline for taking relevant corrective action (before the 31st day after HMRC gives a notice of binding to the taxpayer) and provides a definition of the subsequent closed period during which the taxpayer cannot make any GAAR-related adjustments.

Issue: 1537
Categories: News