GAAR Advisory Panel opinion: extraction of value using a bond and gilt options
Released 02 July 2019
The GAAR Advisory Panel has issued an opinion that arrangements using a bond and gilt options to extract shareholder value were abusive tax arrangements.
GAAR Advisory Panel opinion of 28 May 2019: extraction of value using a second hand bond, gilt options, additional contributions and 'cooling off rights' sets out the GAAR Advisory Panel’s opinion that the extraction of value by shareholders via joint acquisition by company and its shareholders of a second hand bond, and use of gilt option, additional contribution and “cooling off” rights was not a reasonable course of action in relation to the relevant tax provisions. The arrangements were commercially comparable to a dividend or other cash distribution.