LOANS

With all the publicity that has surrounded other parts of FA 2025, practitioners could be forgiven for having missed the changes to the loans to participators regime tucked away in s 81. The rules: The ‘loans to participators’ rules in...

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.

Upper Tribunal finds home loan scheme effective.

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...

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.

FTT varies information notice.

Zoe Andrews

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).

Sean Wright

Deepesh Upadhyay

Deepesh Upadhyay and Sean Wright (Eversheds Sutherland) review the Upper Tribunal’s decision in Hargreaves which considers withholding tax and interest payments.

Helen Buchanan

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.