CTA

Ashley Greenbank (Devereux Chambers) considers the Court of Appeal’s decision in Muller, which raises important questions about the application of the CTA 2009 s 1259 deeming rule to partnership and LLP restructurings involving corporate members.

Aparna Nathan

The Court of Appeal has clarified when remuneration and pension provision will satisfy the ‘wholly and exclusively’ test – and when a tax avoidance purpose will defeat a deduction, writes Aparna Nathan KC (Devereux Chambers).

Mike Lane

Zoe Andrews

The latest developments that matter, reported by Mike Lane and Zoe Andrews (Slaughter and May).

Anna Lucey

Constantine Christofi

HMRC’s nudge campaign signals a broader challenge to deductibility under CTA 2009 s 1219, write Anna Lucey and Constantine Christofi (EY).

Hannah Manning

Ross McGregor

In the first of two articles examining the close companies rules, Hannah Manning and Ross McGregor (Travers Smith) explain why it should not be assumed that a company is not close without looking carefully at the relevant legislation.

Hugh Gunson

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...

Payments to an Ireland government agency were not deductible under the loan relationship rules

Profits arose from oil extraction activities

Scope and operation of the ‘imported loss’ restriction in CTA 2009 s 327 for loan relationships

Ellen Wildig

Sarah Ling

Sarah Ling and Ellen Wildig (Macfarlanes) explore the wider impact for family-controlled businesses of the upcoming reforms to business property relief.

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