23 April 2026Publication
Interest free loans to employees as earnings?
The Court of Appeal has held that a loan to an employee will not normally amount to earnings (ignoring the application of the disguised remuneration rules).
Our tax experts work in three broad areas: transactional support, contentious tax and tax advisory.
We advise clients throughout our European network across the four sectors our firm focuses on:
- Asset management and investment funds
- Financial institutions
- Healthcare and life sciences
- Technology, media and telecommunications
Straddling our advisory and contentious activities are transfer pricing and specialist VAT practices, both led by partners recruited from the big four consultancy firms.
Our multidisciplinary tax team includes lawyers, accountants and economists. This breadth of expertise helps us see the bigger picture for our clients, including the potential for audit issues, regulatory implications, as well as reputational concerns. That means we can tackle high-value complex matters.
We’re smaller and nimbler, meaning we can offer the highest quality advice tailored to our clients’ specific needs, delivered quickly and focused on practical solutions.
Our experience
UK government
Advising on the proposed £28bn merger between BAE Systems and EADS N.V.
British Land
Advising in relation to the exit of joint venture partner, London & Stamford, from its Meadowhall joint venture and the establishment of a new joint venture with Norges Bank Investment Management.
Actief Holding N.V.
Advising on its acquisition of German ISU group
Key contacts
If you have any questions, contact a member of the Tax team for assistance:
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Treaty WHT exemption and main purpose
The sale of a loan to an entity in a better economic position due to the availability of treaty exemption was not contrary to treaty anti-abuse provisions
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Statutory expenditure and attribution of VAT
Expenditure on equipment required by statute to carry on a business was not automatically attributable to the business as a whole.
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