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LOANS-TO-PARTICIPATORS


Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’ starpremium
Card image Nick Thornton
Nick Thornton (Fried Frank) explains why clearing the entry conditions of the QAHC regime is only the start, and how accounting treatment, CIR and funding design can derail intended outcomes.
4 March 2026
Reasonable to avoid s 455, but is it an unreasonable charge? premium
Card image David Whiscombe
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.
16 August 2022
Back to basics: tax on loans to participators premium
Card image Paul Townson
Card image Chris Holmes
Paul Townson and Chris Holmes (BDO) provide a back to basics guide and highlight some points to watch in practice.
30 June 2021
Private client review for March 2021 premium
Card image Georgina Walshe
Card image Edward Reed
Edward Reed and Georgina Walshe (Macfarlanes) provide this month’s review of private client developments that matter.
18 March 2021
Indirect loans to participators premium
Card image Natasha Kaye
Card image 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.
8 July 2020
Close company loans and participators premium
Card image David Southern QC

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

9 February 2017
Ask an expert: Loans to participators – repayment of loan premium
Card image Paula Tallon

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

12 June 2014
Ask an expert: Is this loan a ‘chargeable payment’?
Card image Jeffrey Webber

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

15 May 2014
Tax and the City briefing for March 2014 premium
Card image Helen Lethaby

Helen Lethaby reviews recent developments affecting the City

13 March 2014
Private client briefing for January 2014 premium
Card image Wendy Walton
Card image Miranda Chamberlain

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

30 January 2014
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