The loan relationships rules brought into focus the need for tax advice on the relations between group companies.

On the sale of subsidiaries, corporate groups may benefit from the substantial shareholdings exemption which reduces the tax due on a disposal.

Richard Pincher is a recognised authority on the tax treatment of loan relationships having written a commentary on the provisions when first enacted for Butterworth's Finance Act Handbook.

We can also:

• offer a review of your group's intra group relations to avoid a significant tax issue.
• help structure a deal for you to use substantial shareholding relief to produce a significant tax saving.