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The general anti-abuse rule (The GAAR):

1. •

   counteracts (by the making of adjustments on a just and reasonable basis by HMRC or the taxpayer)

2. •

   tax advantages that would, ignoring the GAAR, arise from abusive Tax arrangements, and

3. •

   has applied since 17 July 2013 (the date of Royal Assent to the Finance Act 2013 (FA 2013)) except that, in respect of National Insurance contributions (NICs), it has only applied since 13 March 2014

This Practice Note explains:

1. •

   that the GAAR can be applied by taxpayers or HMRC

2. •

   how to determine what adjustments to make to counteract abusive tax advantages

3. •

   the procedure for counteraction by HMRC, including:

   1. â—¦

      the different types of notices that HMRC can give a taxpayer and the different GAAR procedures that relate to such notices

   2. â—¦

      the fact that adjustments specified in any such notice become final and the notice itself is treated as if it were given as a final GAAR counteraction notice if the taxpayer does not appeal against the making of the adjustments specified in the notice