The most significant feature of the report is the recommendation that a GAAR should be introduced although it should be targeted solely at "contrived and artificial schemes" and should not apply to "sensible and responsible tax planning".

This article reviews the report and sets out the conditions for the proposed GAAR to apply noting the features which the report proposes to prevent HMRC from using the GAAR indiscriminately, including the creation of an Advisory Panel to oversee the application of the GAAR.

 
 

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