Mandipa Soni examines the loan relationship unallowable purpose rule.
HMRC is increasingly testing the scope of such provisions, as evidenced recently by the First-tier Tribunal (FTT) decision Oxford Instruments UK 2013 Ltd v HMRC [2019] UKFTT 254, in which it was held that a loan entered into as a final step in a debt restructuring had an ‘unallowable purpose’.
This article explores the unallowable purpose rule and its wider application to companies and advisers in determining the scope of tax relief available.
Continue reading
This content is not freely available. To access 'On purpose' you need to be one of the following:
ACA student
This content is available to ACA students. If you want to start the ACA qualification there are several routes you can take
Business and Finance Professional
An internationally recognised designation and professional status from the ICAEW.
ICAEW member
Gain access to world-leading information resources, guidance and local networks. 98% of the best global brands rely on ICAEW chartered accountants.
Tax Faculty
Expert guidance and a wealth of technical and practical resources and support you can trust to keep you on top of tax.