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LOAN-NOTES


The Autumn Budget 2025 tightens anti-avoidance rules for share reorganisations. Peter Morley and Jamie Robson (Pinsent Masons) explain what tax professionals need to be aware of.
Mandipa Soni and Edward Brown (Grant Thornton) discuss the taxation of loan relationships and derivatives for UK corporates, with a focus on convertible securities from the borrower’s perspective.

Karen Bowen, a tax director at Francis Clark, answers questions on HMRC's recent change in practice.

Anthony and Tracy Hancock v HMRC illustrates the limits of both the Ramsay doctrine and the purposive construction of legislation. Pete Miller (The Miller Partnership) takes a look at the case

William Arrenberg and Michael Alliston examine the tax implications of the different ways of effecting public takeovers and mergers.

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