Looking beyond

Alex Helliwell, Andy Lymer and Lynne Oats look beyond the GAAR to loan relationship avoidance

The 2011 Aaronson Report expressed the hope that the introduction of a GAAR (General Anti-Abuse Rule) would simplify tax avoidance legislation (Graham Aaronson, ‘GAAR Study: A Study to Consider Whether a General Anti-Avoidance Rule Should Be Introduced into the UK Tax System’, 2011). However, for many companies in the UK at least, there appears to be only limited evidence to date that this is the case. In this article we review how the GAAR and the Targeted Anti-Avoidance Rule (TAAR) specific to loan relationships continue to interact at present.