UK Tax Focus

Unallowable Purpose - The State Of Play


Unallowable Purpose - The State Of Play

19 September 2019, 12.00 BST
Host: Ben Moseley
Presenters: Helen Chadwick, Mo Malhotra, Gemma Marshall

The ‘Loan Relationships for Unallowable Purposes’ rule has been with us since 1996, but its importance has increased substantially in the last eight years, with a number of Tribunal and Court cases exploring the boundaries of the provision, and increased HMRC enquiry activity.

The rule can disallow deductions arising to companies from loans and transactions in loans (with an equivalent rule for derivatives), and in this session, we’ll explore the current state of the case law, including what it tells us about three main building blocks of the provision.

We'll discuss:

    • ‘Tax advantage’
    • ‘Main purpose’
    • ‘Just and reasonable apportionment’ of debits and credits.

Join us for an update on the practical aspects of this important provision.

Register for this webcast

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