In our latest Tax. Simplified. podcast, Tax Senior Associate Siv Devakumar and Associate Lewis Currie consider the recent case law developments on the unallowable purpose rule.
The unallowable purpose rule is a statutory test which is part of the tax rules relating to corporate debt – it can apply to disallow interest deductions for a UK corporate taxpayer if it's party to the loan in question for a main tax avoidance purpose. Siv and Lewis discuss the recent case law developments in relation to this rule and explain why these could be significant for taxpayers.
Please note that this podcast is for information purposes only. It is not legal advice and should not be relied upon. It is not a substitute for taking specific legal advice in any particular situation. No liability is accepted by Travers Smith, its employees, partners or any other person for the content of this podcast or for the consequences of any action taken or not taken in reliance upon it.