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General Anti-abuse Rule Advisory Panel

Question for Treasury

UIN 237715, tabled on 27 March 2019

To ask the Chancellor of the Exchequer, what proportion of cases referred to the General Anti-Abuse Rule Advisory Panel by HMRC resulted in positive determinations in 2018.

Answered on

1 April 2019

The General Anti-Abuse Rule (GAAR) penalty applies to tax arrangements entered into on or after 15 September 2016. Before a GAAR penalty can be charged, HMRC must first enquire into tax returns once they are received and gather all relevant facts.

Whilst no penalties have been charged to date, HMRC is actively using the GAAR to tackle tax avoidance. To date, all cases referred to the GAAR Advisory Panel have resulted in a Panel opinion in HMRC’s favour. GAAR Panel opinions are published online at:

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