How loans can deny the Substantial Shareholding Exemption (SSE)
9th January 2026
Posted in Articles by Forbes Dawson
The Substantial Shareholding Exemption (SSE) should generally apply to disposals by companies of trading subsidiaries if the shareholding is at least…
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Update – you can still take a cheap mortgage from your company!
28th March 2025
Posted in Articles by Josh Barlow
Perhaps unsurprisingly, HMRC has announced that the official rate of interest (ORI) for employee loans will increase. Perhaps surprisingly, it is…
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Avoid shareholder debt write-offs in corporate transactions
28th February 2025
Posted in Articles by Andrew Marr
Most of you will know about the tax issues surrounding overdrawn directors’ loan accounts, but it is fairly common for shareholders…
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What’s so bad about bridging loans in a section 162 incorporation?
26th July 2024
Posted in Articles, Capital Gains Tax by Andrew Marr
The use of bridging loans in a section 162 incorporation have recently incurred the wrath of tax blogger, Dan Neidle (famous…
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New restrictions to company purchase of own shares rules
4th March 2022
Posted in Articles by Andrew Marr
The issue A basic legal requirement for a company purchase of own shares (CPOS) is that it takes place for cash…
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Retained income and ten year charges
16th October 2020
Posted in Articles, Trusts and Estates by Andrew Marr
The issue In general terms, most trusts established on or after 22 March 2006 are subject to the ‘relevant property’ regime…
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Discharge of a director’s loan account on liquidation is not a write-off!
22nd November 2019
Posted in Articles, Business Tax, Capital Gains Tax by Forbes Dawson
The issue There have been various rumours circulating about a HMRC ‘test case’ with the following key points: A director’s loan…
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