By Aidan Grant

HMRC has updated its guidance regarding relevant loans, which may have a significant impact on the wider use of debt financing in offshore estate planning.

The industry was just coming to terms with the idea that, where money is made available under a loan for the purpose of (generally speaking) purchasing a UK residential property, the benefit of that loan is taxable to IHT in the hands of the lender. HMRC’s new guidance has confirmed that whether or not a relevant loan is chargeable to IHT may depend on whether the loan is secured against the property in question.