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LOANS
Other cases that caught our eye: 7 February 2025
Employee loan arrangements: FS Capital Ltd and others v A Adams and others [2025] EWCA Civ 53 (28 January) is yet another twist in the long saga of employee loan arrangements and their resolution. It is not a tax case as such but will be of interest...
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.
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5
EDITOR'S PICK
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
1 /7
Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency
Hartley Foster
2 /7
Hotel La Tour: where next for input tax recovery on share disposals?
Rupert Shiers
,
Laura Hodgson
3 /7
Mandatory agent registration: what we know so far
Jane Mellor
4 /7
Permanent Establishment reform: what has changed, who is affected and why does it matter?
Rob Sharpe
,
Iarlaith McCarthy-Hann
5 /7
The Pillar Two Side-by-Side package: how UK groups should approach compliance
Jack Gifford
6 /7
Share reorganisations: new anti-avoidance rules explained
Peter Morley
,
Jamie Robson
7 /7
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency
Hartley Foster
Hotel La Tour: where next for input tax recovery on share disposals?
Rupert Shiers
,
Laura Hodgson
Mandatory agent registration: what we know so far
Jane Mellor
Permanent Establishment reform: what has changed, who is affected and why does it matter?
Rob Sharpe
,
Iarlaith McCarthy-Hann
The Pillar Two Side-by-Side package: how UK groups should approach compliance
Jack Gifford
Share reorganisations: new anti-avoidance rules explained
Peter Morley
,
Jamie Robson
NEWS
Read all
HMRC step up VAT scrutiny as large and medium sized-business investigations rise 31%
Government announces increase to Electricity Generator Levy
CIR returns
HMRC issue updated VAT road fuel scale charges
CCA scheme extended to new sectors and updated guidance issued
CASES
Read all
Orsted West of Duddon Sands (UK) Ltd (now named Orsted Schroders Greencoat WODS Holdco Ltd) and others v HMRC
Centrica Energy Storage Ltd v HMRC
Clearwater Hampers Ltd v HMRC
Other cases that caught our eye: 24 April 2026
CATS North Sea Ltd v HMRC
IN BRIEF
Read all
IHT and pensions
Mega Marshmallows and the meaning of ‘normally’
ATED: a reminder
UK short-term business visitors: the Appendix 4 report
Tax advisers: sanctionable conduct
MOST READ
Read all
Tax advisers: sanctionable conduct
Section 171A elections
HMRC loans to participators tool
Mega Marshmallows and the meaning of ‘normally’
Centrica Energy Storage Ltd v HMRC