The MJP Media case raises an important issue relating to the application of the loan relationships regime, namely whether a payment made by person A to person C, for the benefit of and with the agreement of person B, can give rise to a loan relationship as between person A and person B. This issue impacts on the tax treatment of some commonplace transactions. The recent decision of the Upper Tribunal is less unhelpful on the point than the decision of the First-tier Tribunal, but still leaves the question open.
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