½Û×ÓÊÓÆµ

Commentary

A7.411 GAAR—overview

Administration and compliance

The general anti-abuse rule (GAAR) is another element of HMRC's approach to tackling tax avoidance and is not intended to replace or supersede targeted anti-avoidance rules or any obligations under DOTAS. See A7.410. It has effect generally in relation to any tax arrangements entered into on or after 17 July 2013. Where the tax arrangements under consideration form part of other arrangements entered into before 17 July 2013, those other arrangements should be ignored in determining whether the tax arrangements in question are abusive1.

Note that the Scotland and Wales have their own versions of the GAAR in respect of devolved taxes, see A1.535 (Scotland) and A1.543 (Wales).

Taxes to which the GAAR applies

The GAAR provides for the counteraction (see A7.412) of tax advantages arising from arrangements that are abusive and applies to2:

  1. Ìý

    •ÌýÌýÌýÌý income tax

  2. Ìý

    •ÌýÌýÌýÌý corporation tax (including amounts chargeable/treated as corporation tax)

  3. Ìý

    •ÌýÌýÌýÌý capital gains tax

  4. Ìý

    •ÌýÌýÌýÌý petroleum revenue tax

  5. Ìý

    •ÌýÌýÌýÌý inheritance tax

  6. Ìý

    •ÌýÌýÌýÌý stamp duty land tax

  7. Ìý

    •

To continue reading
View the latest version of this document, as well as thousands of others like it, sign in to Tolley+™ Research or register for a free trial

Web page updated on 17 Mar 2025 15:43