In the article available at the link below, our London Tax team share their experience of the approach the UK tax authority (HMRC) is taking to unallowable purposes enquires, with a focus on the loan relationship unallowable purposes rules which seem to be particularly in vogue as HMRC tackles what it perceives to be artificial (mainly intragroup) financing structures.

This article was originally published in Tax Journal on 17 February 2023.