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LOANS


A new chapter in the unallowable purpose tale: the FTT’s decision in Syngenta premium
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
Tax and the City review for September 2021 premium
Card image Zoe Andrews
Card image Mike Lane
This month’s review by Mike Lane and Zoe Andrews (Slaughter and May).
8 September 2021
Private client review for July 2021 premium
Card image Charlotte Kynaston
Card image Edward Reed
Edward Reed and Charlotte Kynaston (Macfarlanes) provide this month’s review of developments affecting private clients.
15 July 2021
Back to basics: tax on loans to participators premium
Card image Paul Townson
Card image Chris Holmes
Paul Townson and Chris Holmes (BDO) provide a back to basics guide and highlight some points to watch in practice.
30 June 2021
EDITOR'S PICKstar
NEWSRSS Read all
NICs Bill published
19 November 2024
CASESRSS Read all
Generator Power Ltd v HMRC
20 November 2024
Syngenta Holdings Ltd v HMRC
13 November 2024
IN BRIEFRSS Read all
MOST READ Read all
Syngenta Holdings Ltd v HMRC
13 November 2024
Finance Bill 2025 published
13 November 2024
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