GAAR Advisory Panel ruling on estate value reduction and Inheritance Tax avoidance through share transfers to employee trusts

HMRC has released a General Anti-Abuse Rule Advisory Panel opinion dated 30 January 2026 examining whether arrangements involving the purchase of company shares and their subsequent gifting to an employee trust constitute abusive tax avoidance under GAAR. The guidance is designed to help businesses and advisers identify characteristics of potentially abusive arrangements in the context of Inheritance Tax planning, particularly where the primary purpose appears to be artificial estate reduction or circumventing Inheritance Tax on lifetime transfers rather than achieving genuine commercial objectives.

Source: HMRC (GOV.UK) – Read the original