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LOANS


Elborne: trusting that the loan will be deducted premium
Card image Anthony Nixon
Anthony Nixon (Paris Smith) examines the first judicial ruling to accept that the double trust home loan scheme works to save inheritance tax.
19 March 2025
The executors of L Elborne deceased and others v HMRC premium
Upper Tribunal finds home loan scheme effective.
26 February 2025
Other cases that caught our eye: 7 February 2025 premium
Employee loan arrangements: FS Capital Ltd and others v A Adams and others [2025] EWCA Civ 53 (28 January) is yet another twist in the long saga of employee loan arrangements and their resolution. It is not a tax case as such but will be of interest...
5 February 2025
A new chapter in the unallowable purpose tale: the FTT’s decision in Syngenta starpremium
Card image Tanja Velling
Tanja Velling (Slaughter and May) reviews a significant FTT decision in which the taxpayers were denied interest deductions on a loan created in an intra-group reorganisation under the unallowable purpose rule.
20 November 2024
S Sangha v HMRC premium
FTT varies information notice.
10 July 2024
Tax and the City review for November 2023 premium
Card image Zoe Andrews
Card image Mike Lane
Target Group, Vermilion and changes to HMRC’s guidance on the double tax treaty passport scheme are among the  developments examined by Mike Lane and Zoe Andrews (Slaughter and May).
8 November 2023
Withholding tax: Hargreave-ances premium
Card image Sean Wright
Card image Deepesh Upadhyay
Deepesh Upadhyay and Sean Wright (Eversheds Sutherland) review the Upper Tribunal’s decision in Hargreaves which considers withholding tax and interest payments.
21 June 2023
How to handle unallowable purposes enquiries starpremium
Card image Helen Buchanan
Card image Sarah Bond
Helen Buchanan and Sarah Bond (Freshfields Bruckhaus Deringer) share their experience of the approach HMRC is taking to unallowable purposes enquiries, in particular under CTA 2009 s 441.
15 February 2023
Investment into and expansion within the UK: acquisition planning premium
Card image Helena Kanczula
When structuring a UK acquisition, there are a myriad of tax issues to consider, as Helena Kanczula (BKL) explains.
15 February 2023
Taxation of loan transfers premium
Card image David Southern QC
David Southern QC (Field Court Tax Chambers) provides a guide to the tax consequences of loan transfers.
9 November 2021
EDITOR'S PICKstar
NEWSRSS Read all
Finance Act 2025 enacted
28 March 2025
CASESRSS Read all
PD & MJ Ltd v HMRC
27 March 2025
LR R&D LLP v HMRC
27 March 2025
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When is 20% not 20%?
19 March 2025
MOST READ Read all
V Louwman v HMRC
19 March 2025
B Lynch v HMRC
19 March 2025
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