Change of https://www.gov.uk/government/publications/gaar-advisory-panel-opinion-of-30-january-2026-reducing-the-value-of-an-estate-for-inheritance-tax-and-avoiding-inheritance-tax-on-a-lifetime-transfer

Change description : 2026-05-12 11:27:00: First published. [Guidance and regulation]

Showing diff : ..2026-05-12 10:27:40.500538446 +00:00

Guidance

GAAR Advisory Panel opinion of 30 January 2026: reducing the value of an estate for Inheritance Tax and avoiding Inheritance Tax on a lifetime transfer by acquiring shares in a company and gifting those shares to an employee trust

Use the General Anti-Abuse Rule (GAAR) Advisory Panel opinion to help you recognise when arrangements may be abusive tax arrangements.

From:
HM Revenue & Customs
Published
12 May 2026

Documents

Reducing the value of an estate for Inheritance Tax and avoiding Inheritance Tax on a lifetime transfer by acquiring shares in a company and gifting those shares to an employee trust — PR1

ODT, 28 KB

This file is in an OpenDocument format

This file may not be suitable for users of assistive technology.

Request an accessible format.
If you use assistive technology (such as a screen reader) and need a version of this document in a more accessible format, please email different.format@hmrc.gov.uk. Please tell us what format you need. It will help us if you say what assistive technology you use.

Reducing the value of an estate for Inheritance Tax and avoiding Inheritance Tax on a lifetime transfer by acquiring shares in a company and gifting those shares to an employee trust — PR2

ODT, 28 KB

This file is in an OpenDocument format

This file may not be suitable for users of assistive technology.

Request an accessible format.
If you use assistive technology (such as a screen reader) and need a version of this document in a more accessible format, please email different.format@hmrc.gov.uk. Please tell us what format you need. It will help us if you say what assistive technology you use.

Reducing the value of an estate for Inheritance Tax and avoiding Inheritance Tax on a lifetime transfer by acquiring shares in a company and gifting those shares to an employee trust — PR3

ODT, 27.7 KB

This file is in an OpenDocument format

This file may not be suitable for users of assistive technology.

Request an accessible format.
If you use assistive technology (such as a screen reader) and need a version of this document in a more accessible format, please email different.format@hmrc.gov.uk. Please tell us what format you need. It will help us if you say what assistive technology you use.

Reducing the value of an estate for Inheritance Tax and avoiding Inheritance Tax on a lifetime transfer by acquiring shares in a company and gifting those shares to an employee trust — Trustee

ODT, 28.1 KB

This file is in an OpenDocument format

This file may not be suitable for users of assistive technology.

Request an accessible format.
If you use assistive technology (such as a screen reader) and need a version of this document in a more accessible format, please email different.format@hmrc.gov.uk. Please tell us what format you need. It will help us if you say what assistive technology you use.

Details

Use this opinion together with the General Anti-Abuse Rule (GAAR) guidance to help you recognise when arrangements may be abusive tax arrangements.

This opinion covers the avoidance of Inheritance Tax, by acquiring shares in a company and gifting those shares to an employee trust to:

  • avoid Inheritance Tax on a lifetime transfer
  • reduce the value of an estate for Inheritance Tax

The GAAR Advisory Panel’s opinion is that:

  • entering into the tax arrangements is not a reasonable course of action in relation to the relevant tax provisions
  • carrying out of the tax arrangements is not a reasonable course of action in relation to the relevant tax provisions

Updates to this page

Published 12 May 2026

Sign up for emails or print this page

Update history

2026-05-12 11:27
First published.