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Home
Loans
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LOANS
A new chapter in the unallowable purpose tale: the FTT’s decision in Syngenta
Tanja Velling
Tanja Velling (Slaughter and May) reviews a significant FTT decision in
which the taxpayers were denied interest deductions on a loan created in an
intra-group reorganisation under the unallowable purpose rule.
S Sangha v HMRC
FTT varies information notice.
Tax and the City review for November 2023
Zoe Andrews
Mike Lane
Target Group
,
Vermilion
and changes to HMRC’s guidance on the double tax
treaty passport scheme are among the developments examined by Mike Lane
and Zoe Andrews (Slaughter and May).
Withholding tax: Hargreave-ances
Sean Wright
Deepesh Upadhyay
Deepesh Upadhyay and Sean Wright (Eversheds Sutherland) review the Upper Tribunal’s decision in Hargreaves which considers withholding tax and interest payments.
How to handle unallowable purposes enquiries
Helen Buchanan
Sarah Bond
Helen Buchanan and Sarah Bond (Freshfields Bruckhaus Deringer) share
their experience of the approach HMRC is taking to unallowable purposes
enquiries, in particular under CTA 2009 s 441.
Investment into and expansion within the UK: acquisition planning
Helena Kanczula
When structuring a UK acquisition, there are a myriad of tax issues to
consider, as Helena Kanczula (BKL) explains.
Taxation of loan transfers
David Southern QC
David Southern QC (Field Court Tax Chambers) provides a guide to the tax consequences of loan transfers.
Tax and the City review for September 2021
Zoe Andrews
Mike Lane
This month’s review by Mike Lane and Zoe Andrews (Slaughter and May).
Private client review for July 2021
Charlotte Kynaston
Edward Reed
Edward Reed and Charlotte Kynaston (Macfarlanes) provide this month’s review of developments affecting private clients.
Back to basics: tax on loans to participators
Paul Townson
Chris Holmes
Paul Townson and Chris Holmes (BDO) provide a back to basics guide and highlight some points to watch in practice.
Go to page
of
5
EDITOR'S PICK
Management expenses: HMRC’s new nudge campaign
Anna Lucey
,
Constantine Christofi
1 /7
Medpro: better late than never
Stacey Cranmore
2 /7
No escape: the new IHT tax rules for pensions
Harriet Betteridge
3 /7
What time is it? A review of the Supreme Court’s decision in Prudential
David Jamieson
4 /7
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
,
Elvira Colomer Fatjo
5 /7
Understanding the FIG regime
Jo Bateson
6 /7
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
7 /7
Management expenses: HMRC’s new nudge campaign
Anna Lucey
,
Constantine Christofi
Medpro: better late than never
Stacey Cranmore
No escape: the new IHT tax rules for pensions
Harriet Betteridge
What time is it? A review of the Supreme Court’s decision in Prudential
David Jamieson
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
Understanding the FIG regime
Jo Bateson
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
NEWS
Read all
HMRC manual changes: 7 November 2025
Post Office Capture Redress Scheme tax exemptions
Chancellor seeks to reassure markets ahead of Budget
Welsh Government publishes second stage of Draft Budget
New regs pave way for delegation of HMRC PAYE functions
CASES
Read all
Northumbria Healthcare NHS Foundation Trust v HMRC
J Boulting v HMRC
HMRC v Ducas Ltd
Other cases that caught our eye: 7 November 2025
Illuminate Skin Clinics Ltd v HMRC
IN BRIEF
Read all
Exclusive purposes
‘Partnership NICs’: the impact on the asset management sector
Time to bring back Budget purdah?
Transfer pricing ‘high-value’ intragroup services
Autumn Budget 2025: what tax measures can we expect?
MOST READ
Read all
Tyler Security Ltd v HMRC
Time to bring back Budget purdah?
‘Partnership NICs’: the impact on the asset management sector
Transfer pricing ‘high-value’ intragroup services
Eurocent (Buckingham) Ltd v HMRC