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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.
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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
UK posts record January budget surplus following increased tax receipts
HMRC guidance on R&D relief in the creative sector
Deferred remuneration for globally mobile employees
New guidance on registering for VAT IOSS scheme
Devolved Scottish Aggregates Tax to take effect from 1 April 2026
CASES
Read all
Lycamobile UK Ltd v HMRC
A Ferguson and another v HMRC
Genuine Care Homecare Services Ltd v HMRC
Other cases that caught our eye: 27 February 2026
MWL International Ltd
IN BRIEF
Read all
Crypto things
Tax efficient trust planning with surplus income
Suspended penalties
The Supreme Court hearing in Orsted Sands
Concerns over the scope of new conduct rules for advisers
MOST READ
Read all
Exchequer Secretary defends tax adviser registration regime as Law Society warns of market impact
Mandatory agent registration: what we know so far
Deductions after AD Bly: a shortcut for remuneration or pension provision?
Alimahomed: the Upper Tribunal gives ‘remittance’ a real world interpretation
Consultation tracker