Bhaur & ors v Equity First Trustees (Nevis) Ltd & ors WTLR(w) 2022-01

Wills & Trusts Law Reports | Web Only

GAAR Opinion notice [2020] WTLR 427

Wills & Trusts Law Reports | Summer 2020 #179

By a referral dated 28 October 2019 HMRC referred to the GAAR Advisory Panel arrangements made by B as executor of the estate of his late mother, A, who died in April 2015. Four months before her death A incorporated a company, funded by £700,000 of share capital. The company established a discretionary trust, to which A gifted most of the share capital in the company. The beneficial class of the trust was current and former employees, and their descendants. The only employees of the company were A, B and B’s wife.

B claimed that the gift of shares to the trust was an exempt trans...