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Home
Loans
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LOANS
The executors of L Elborne deceased and others v HMRC
Upper Tribunal finds home loan scheme effective.
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
Mike Lane
Zoe Andrews
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
Deepesh Upadhyay
Sean Wright
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
Sarah Bond
Helen Buchanan
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
Mike Lane
Zoe Andrews
This month’s review by Mike Lane and Zoe Andrews (Slaughter and May).
Go to page
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5
EDITOR'S PICK
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
1 /7
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Alan Rafferty
,
Jade Du Berry
,
Ollie Winters
2 /7
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
3 /7
Loopholes and tax avoidance
Kyle Rainsford
4 /7
Spare us the cUTTer
Nick Thornton
5 /7
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
6 /7
Muller: notional companies and real-world transactions
Ashley Greenbank
7 /7
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Alan Rafferty
,
Jade Du Berry
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
Loopholes and tax avoidance
Kyle Rainsford
Spare us the cUTTer
Nick Thornton
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
Muller: notional companies and real-world transactions
Ashley Greenbank
NEWS
Read all
Tax Update 2026: government publishes simplification and compliance package
HMRC asked to clarify CIS treatment of development finance
HMRC Transfer Pricing and Profit Diversion Compliance Facility
ICTS consultation
UK-India Double Contributions Convention arrangements extended
CASES
Read all
HMRC v HFFX LLP; Atkins and others v HMRC
The Trustees of the Panico Panayi Accumulation and Maintenance Settlements Nos. 1 to 4 v HMRC and Redevco Properties UK 1 Ltd v HMRC
Other cases that caught our eye: 26 June 2026
HMRC v Bolt Services UK Ltd
Barclays Bank plc v HMRC
IN BRIEF
Read all
Foreign PE exemption becoming mandatory
Solving the LLC double taxation problem
AI in R&D advisory: seven control points
Information notices
Management rollovers and share-for-share exchange relief
MOST READ
Read all
Solving the LLC double taxation problem
Consultation tracker
HMRC v GCH Corporation Ltd and others
Foreign PE exemption becoming mandatory
HMRC consult on taxation of UK-resident members of LLCs and other ‘reverse hybrids’