LOANS-TO-PARTICIPATORS

David Whiscombe (BKL) reviews the first GAAR Panel decision in favour of the taxpayer and argues that the underlying legislation is long overdue for repeal.

Paul Townson

Chris Holmes

Paul Townson and Chris Holmes (BDO) provide a back to basics guide and highlight some points to watch in practice.

Edward Reed

Georgina Walshe

Edward Reed and Georgina Walshe (Macfarlanes) provide this month’s review of private client developments that matter.

Natasha Kaye

Reshma David

Natasha Kaye and Reshma David (Cooley) examine the scope of the close company indirect loan to participator rule in CTA 2010 s 459.

David Southern QC

David Southern QC (Temple Tax Chambers) considers the important distinction between loans to participators and loans by participators.

Paula Tallon

Paula Tallon answers a query on a loan to a participator in a close company in light of FA 2013 changes

Jeffrey Webber

Jeff Webber answers a query on whether a loan could be caught as a ‘chargeable payment’ under CTA 2010 s 1088.

Helen Lethaby

Helen Lethaby reviews recent developments affecting the City

Miranda Chamberlain

Wendy Walton

Wendy Walton and Miranda Chamberlain sift through the draft Finance Bill measures affecting the taxation of private clients

Paula Tallon

Paul Howard

The rules have tightened with effect from 20 March. Paula Tallon and Paul Howard explain why the new provisions may force companies to consider the true nature of transactions with their shareholders.