LOAN-RELATIONSHIPS

Andrew Stewart (BDO) explores the new transfer pricing treatment of forex movements and highlights the additional compliance burden and technical uncertainty introduced by FA 2026.

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

Part of loan relationship loss disallowed as referable to period of non-UK tax residence.

Court of Appeal affirms a wide application of the loan relationships unallowable purpose test.

Sarah Bond

Helen Buchanan

The Court of Appeal judgment restores order, write Sarah Bond and Helen Buchanan (Freshfields Bruckhaus Deringer).

Court of Appeal overturns Upper Tribunal decision on transfer pricing but upholds conclusion on unallowable purpose.

Mike Lane

Zoe Andrews

Recent decisions on intra-group VAT services, loan relationship debits and distributions from non-UK resident company are examined by Mike Lane and Zoe Andrews (Slaughter and May).

Loan relationship debits disallowed

Mairead Cummins

Mark Whitehouse

Tax Journal’s recent coverage of the Keighley case has largely focused on connected companies issues. Here, Mark Whitehouse and Mairead Cummins (PwC) focus on the other key issue in that case: the ‘gateway test’ for the deductibility of loan relationship debits.

Mike Lane

Zoe Andrews

Keighley on the loan relationship rules, Clipperton on purposive construction and the introduction of the Reserved Investor Fund are among the developments examined by Mike Lane and Zoe Andrews (Slaughter and May).

Go to page of 4