LIQUIDATIONS

Paul Townson

Chris Holmes

Paul Townson and Chris Holmes (BDO) examine the recent changes which are making the loans to participators regime more onerous for close companies and advisers.

Jennifer Plummer

Jennifer Plummer (BDO) considers the requirements for this valuable relief and outlines some of the complexities involved where corporate structures are not straightforward.

Liesl Fichardt

Emily Au

HMRC’s preferential ranking brings into sharp focus their requirements to evidence and substantiate their claims in an insolvency, as Liesl Fichardt and Emily Au (Quinn Emanuel) explain.

Employee ‘loans’ were taxable earnings: In J Lowry v HMRC [2026] UKFTT 1279 (TC) (3 September), the FTT dismissed the taxpayer’s appeal, finding that substantial interest-free ‘loans’ received through an employee remuneration arrangement were taxable...

Director’s loan balance written off on liquidation

Liquidation of parent company to preserve SDLT group relief did not have tax avoidance main purpose

Normal expenditure out of income: J Wood v HMRC [2026] UKFTT 589 (TC) (16 April) is the second recent decision, after Hosking [2026] UKFTT 406 (TC) (see Tax Journal, 27 March 2026), on the limits of the IHT exemption for gifts out of income....

Costs awarded because of taxpayer’s unreasonable conduct: In HMRC v Mattu [2025] UKUT 410 (TCC) (16 December 2021), the UT awarded HMRC £5,000 in costs under rule 10(3)(d) of the UT rules (SI 2008/2698), confirming that there is no requirement for a...

Upper Tribunal decides that HMRC lawfully refused late claim under SP 5/01

Director’s loan was not written off or released on liquidation

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