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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
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).
Private client review for July 2021
Edward Reed
Charlotte Kynaston
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.
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of
5
EDITOR'S PICK
Tax Journal's 2025 Budget coverage
1 /7
Management expenses: HMRC’s new nudge campaign
Anna Lucey
,
Constantine Christofi
2 /7
Medpro: better late than never
Stacey Cranmore
3 /7
No escape: the new IHT tax rules for pensions
Harriet Betteridge
4 /7
What time is it? A review of the Supreme Court’s decision in Prudential
David Jamieson
5 /7
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
,
Elvira Colomer Fatjo
6 /7
Understanding the FIG regime
Jo Bateson
7 /7
Tax Journal's 2025 Budget coverage
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
NEWS
Read all
HMRC manual changes: 9 January 2026
Agreement reached on Pillar Two ‘side-by-side’ package
Late change lifts BPR/APR cap
New guidelines on imported hybrid mismatch rules
VAT treatment of supplies of temporary medical staff
CASES
Read all
HMRC v Hotel La Tour Ltd
County Insurance Services Ltd v HMRC
The Tower One St George Wharf Ltd v HMRC
R Sehgal v HMRC
Other cases that caught our eye: 9 January 2026
IN BRIEF
Read all
TSI Instruments and import VAT recovery
Voluntary returns and impossible penalties
Budget 2025 changes to the share exchanges and reorganisation rules
Fixing the FIG regime before extending it
Welsh Government consults on LTT and other tax changes
MOST READ
Read all
Finance Bill 2026 published
Tax in 2025: the good, the bad and the ugly
A year at the Tax Bar in 2025
End of year musings on corporate tax
R&D tax in 2025: the calm after the storm?