On 30 January 2015, HMRC published revised GAAR guidance (approved by the Advisory Panel), applying to transactions entered into on or after 30 January 2015.
There has been minimal amendment to Parts A to C, which set out the purpose of the guidance and how the GAAR is designed to operate. The examples (contained within part D) have been subject to more substantial amendment, including the addition of a new example (D25A) of an arrangement designed to avoid the disguised remuneration rules contained in Part 7A, ITEPA 2003, which HMRC considers to be abusive.
Some changes have also been made to Part E, particularly a new section on NICs.
To access the revised guidance click here.