Aidan Briggs’ case note on Elborne v HMRC [2025] UKUT 00059 (TCC)

This decision is required reading for any Private Client practitioners dealing with the estates of those who attempted ‘Home Loan’ tax avoidance schemes, of which many thousands were created between 1995 and 2003. These schemes are complex and often poorly-implemented, and this decision addresses the tax consequences and represents a dramatic shift from the position as previously understood.

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