LOAN-NOTES

Mandipa Soni and Edward Brown (Grant Thornton) discuss the taxation of loan relationships and derivatives for UK corporates, with a focus on convertible securities from the borrower’s perspective.

Karen Bowen, a tax director at Francis Clark, answers questions on HMRC's recent change in practice.

Anthony and Tracy Hancock v HMRC illustrates the limits of both the Ramsay doctrine and the purposive construction of legislation. Pete Miller (The Miller Partnership) takes a look at the case

William Arrenberg and Michael Alliston examine the tax implications of the different ways of effecting public takeovers and mergers.