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Home
Loan relationships
Home
Loan relationships
LOAN-RELATIONSHIPS
J Keighley and another v HMRC
Private use of company credit card and tax treatment of loan write off.
Tax and the City review for September 2023
Zoe Andrews
Mike Lane
In this month’s review, Mike Lane and Zoe Andrews (Slaughter and May) consider the Upper Tribunal decisions in
JTI Acquisitions
and
Hotel La Tour
, and HMRC’s latest annual report.
Tax and the City review for June 2023
Zoe Andrews
Mike Lane
In this month’s review, Mike Lane and Zoe Andrews (Slaughter and May) consider HMRC’s updated unallowable purpose guidance, an advocate general opinion on state aid challenges to tax rulings and an Upper Tribunal case which raises some interesting points on distributions and procedural fairness.
Tax and the City review for June 2022
Zoe Andrews
Mike Lane
The latest developments that matter, reviewed by Mike Lane and Zoe Andrews (Slaughter and May).
JTI Acquisition: the FTT casts a wide net on unallowable purpose
Oliver Marre
Oliver Marre (5 Stone Buildings) examines a First-tier Tribunal decision that is important for anyone considering inter-group loan structuring.
Shinelock: loan relationships and late claims
David Whiscombe
Shinelock fails to extract pounds of tax relief from HMRC. David Whiscombe (BKL) reviews a case on loan relationships with some intriguing procedural issues.
Guarantees revisited
Stuart Pibworth
Jenny Doak
Jenny Doak and Stuart Pibworth (Weil, Gotshal & Manges) revisit some of the key UK corporation and withholding tax considerations to consider on guarantees of financial obligations.
Taxation of cryptoassets for businesses
Robert Langston
Robert Langston (Saffery Champness) considers new HMRC guidance that provides some clarification, although there are still areas that are left open.
Ladbroke, unallowable purpose and deemed loans
Heather Self
Heather Self (Blick Rothenberg) examines the Court of Appeal judgment in
Ladbroke
and its wider implications.
Tax and the City briefing for April 2018
Zoe Andrews
Mike Lane
Mike Lane and Zoe Andrews (Slaughter and May) review recent developments affecting the City.
Go to page
of
4
EDITOR'S PICK
The Orsted ‘tax nothing’
Andrew Page
1 /7
Budget 2026: options for taxing wealth
Dom Rothbarth
2 /7
HMRC powers and the taxpayer relationship: when is enough, enough?
Chris Sanger
,
Constantine Christofi
,
Craig Kirkham-Wilson
3 /7
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
,
Emily Szasz
,
Joe Williams
,
Tom Gardner
4 /7
Reckless tax statements: a lower threshold for crime?
Adam Craggs
,
Tom Jenkins
5 /7
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
6 /7
The 2026 loan charge settlement scheme: the beginning of the end?
David Pett
7 /7
The Orsted ‘tax nothing’
Andrew Page
Budget 2026: options for taxing wealth
Dom Rothbarth
HMRC powers and the taxpayer relationship: when is enough, enough?
Chris Sanger
,
Constantine Christofi
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
,
Emily Szasz
Reckless tax statements: a lower threshold for crime?
Adam Craggs
,
Tom Jenkins
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
The 2026 loan charge settlement scheme: the beginning of the end?
David Pett
NEWS
Read all
Conservatives pledge IHT exemption for family homes
Government accepts PAC recommendations on large business tax compliance
No breaches found under banks’ tax code
Distributions reform could hinder business transactions, CIOT warns
Bolt: Supreme Court refuses permission to appeal
CASES
Read all
HMRC v British Airways plc
Victoria Oil & Gas plc v HMRC
S Keswick and others v HMRC
Other cases that caught our eye: 9 October 2026
Jumpman Gaming Ltd v HMRC
IN BRIEF
Read all
AI and the unwinnable case
Corporate residence: beyond the paperwork
Hill: the Upper Tribunal on reasonable excuse
Loans to participators: s 455
Modernising the taxation of distributions
MOST READ
Read all
Bolt: Supreme Court refuses permission to appeal
Re Fulmar Contracting Ltd (In Liquidation) and others v M Williams and another
HMRC name 196 deliberate tax defaulters
Victoria Oil & Gas plc v HMRC
Loans to participators: s 455