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Home
Loan relationships
Home
Loan relationships
LOAN-RELATIONSHIPS
UK Care No. 1 Ltd v HMRC
Part of loan relationship loss disallowed as referable to period of non-UK tax residence.
JTI Acquisition Company (2011) Ltd v HMRC
Court of Appeal affirms a wide application of the loan relationships unallowable purpose test.
Back to BlackRock: the Court of Appeal restores order
Helen Buchanan
Sarah Bond
The Court of Appeal judgment restores order, write Sarah Bond and
Helen Buchanan (Freshfields Bruckhaus Deringer).
BlackRock Holdco 5 LLC v HMRC
Court of Appeal overturns Upper Tribunal decision on transfer pricing but upholds conclusion on unallowable purpose.
Tax and the City review for April 2024
Zoe Andrews
Mike Lane
Recent decisions on intra-group VAT services, loan relationship debits and
distributions from non-UK resident company are examined by Mike Lane
and Zoe Andrews (Slaughter and May).
Barclays Bank plc v HMRC
Loan relationship debits disallowed
Writing off a loan: the unallowable purpose trap
Mark Whitehouse
Mairead Cummins
Tax Journal
’s recent coverage of the
Keighley
case has largely focused on connected companies issues. Here, Mark Whitehouse and Mairead Cummins (PwC) focus on the other key issue in that case: the ‘gateway test’ for the deductibility of loan relationship debits.
Tax and the City review for March 2024
Zoe Andrews
Mike Lane
Keighley
on the loan relationship rules,
Clipperton
on purposive construction
and the introduction of the Reserved Investor Fund are among the
developments examined by Mike Lane and Zoe Andrews (Slaughter and May).
J Keighley and another v HMRC
Private use of company credit card and tax treatment of loan write off.
Tax and the City review for September 2023
Zoe Andrews
Mike Lane
In this month’s review, Mike Lane and Zoe Andrews (Slaughter and May) consider the Upper Tribunal decisions in
JTI Acquisitions
and
Hotel La Tour
, and HMRC’s latest annual report.
Go to page
of
4
EDITOR'S PICK
RBC: from the island of literal interpretation to the continental shelf
Victoria Hine
,
Kyle Rainsford
1 /7
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
2 /7
Helping vulnerable individuals: a guide for tax professionals
Chris Holmes
,
Dawn Register
3 /7
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
4 /7
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
5 /7
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
6 /7
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
7 /7
RBC: from the island of literal interpretation to the continental shelf
Victoria Hine
,
Kyle Rainsford
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
Helping vulnerable individuals: a guide for tax professionals
Chris Holmes
,
Dawn Register
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
NEWS
Read all
Tax Journal authors for March
HMRC closing in on tax avoidance (again)
Finance Act 2025 enacted
MPs press ahead with NICs increases
ATED chargeable amounts increased
CASES
Read all
HMRC v Innovative Bites Ltd and another
PD & MJ Ltd v HMRC
LR R&D LLP v HMRC
Other cases that caught our eye: 28 March 2025
Orsted West of Duddon Sands (UK) Ltd and others v HMRC
IN BRIEF
Read all
Excluded property trusts and 6 April 2025
IR35, staffing companies and the small company threshold
Country-by-country reporting goes public
When is 20% not 20%?
Are multiple trusts still a viable IHT planning strategy?
MOST READ
Read all
Orsted West of Duddon Sands (UK) Ltd and others v HMRC
Concerns remain over Making Tax Digital
HMRC closing in on tax avoidance (again)
V Louwman v HMRC
B Lynch v HMRC