Loan relationships – When is a loan not a loan?

Loan relationships – When is a loan not a loan?

The loan relationships provisions for companies have been around since 1996, and it is fair to say that the legislation overall is complex. However, it is not normally difficult to identify a loan relationship for these purposes, although a recent case indicates that even this task may not be without its problems. The loan relationship. Read more

Private residence relief – Married couples ‘living together’ for CGT purposes

Private residence relief – Married couples ‘living together’ for CGT purposes

Married couples (and civil partners) benefit from favourable treatment for certain tax purposes. A common example is the ‘no gain, no loss’ capital gains tax (CGT) treatment for inter-spouse transfers (TCGA 1992, s 58). In addition, the inheritance tax spouse exemption is unlimited for transfers between UK domiciled spouses (although it is restricted to £55,000. Read more

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