Hugh Gunson and Cora Hardy write for Tax Journal on the recent changes to the loans to participators regime under FA 2025
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.
In an article for Tax Journal, Hugh Gunson, Partner, and Cora Hardy, Associate in our Private Wealth Disputes team cover the rules, what's changed, why it has changed and wider implications.
See a snippet of the piece below:
These changes cast the net of the loans to participators regime potentially very widely.
Companies should take care they do not inadvertently fall foul of it while carrying out commercially motivated arrangements. This is particularly so given the TAAR includes the typical form of ‘main purpose’ test which can be difficult to apply (as evidenced by the number of recent cases on such tests in different contexts.
Read the full piece in Tax Journal here.
