LOANS

Naomi Lawton (A&O Shearman) finds much to welcome in the Government’s latest policy statements.

With all the publicity that has surrounded other parts of FA 2025, practitioners could be forgiven for having missed the changes to the loans to participators regime tucked away in s 81. The rules: The ‘loans to participators’ rules in...

Anthony Nixon

Anthony Nixon (Paris Smith) examines the first judicial ruling to accept that the double trust home loan scheme works to save inheritance tax.

Taxpayer breached the extraction of value rule for business investment relief purposes

Court of Appeal confirms that loans made under remuneration trust arrangements were taxable as disguised remuneration

Novation of director’s loan account

Director’s loan was not written off or released on liquidation

Upper Tribunal finds home loan scheme effective.

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...

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.

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