HMRC has published guidance based on a July 2026 GAAR Advisory Panel opinion to assist businesses and advisers in identifying potentially abusive tax arrangements involving disguised remuneration through dual payment structures. The guidance helps stakeholders recognise arrangements that may constitute general anti-abuse rule violations, specifically targeting schemes where payments are structured to obtain tax advantages through disguised salary or employment income arrangements. This panel opinion provides clarity on what HMRC considers abusive in this category of tax avoidance schemes.
Source: HMRC (GOV.UK) – Read the original