Market leading insight for tax experts
View online issue

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.
Share loss relief: S Wilders v HMRC [2026] UKFTT 517 (TC) (1 April) is a claim for share loss relief arising from a failed attempt to recover treasure from the wreck of the ship the Merchant Royal, which sunk in 1641 off Land’s End. Investors...
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.

EDITOR'S PICKstar
Top