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KEY POINTS
- The GAAR panel has an advisory role and HMRC is not obliged to follow its opinions.
- The scheme concerned tripartite arrangements to move assets and liabilities between the employer employee and EBT.
- The panel concluded the arrangements were not a reasonable course of action.
- The opinion will allow HMRC to issue accelerated payment notices.
This was accepted and after much discussion the GAAR was introduced...
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