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Home / Simons-Taxes /Personal and employment tax /Part E1 Income tax /Division E1.8 Annual payments by non corporate bodies, donations to charity, qualifying loan interest /Relief for qualifying loan interest paid by individuals and personal representatives / E1.830A Qualifying loan interest—loan taken out by personal representatives to pay inheritance tax

E1.830A Qualifying loan interest—loan taken out by personal representatives to pay inheritance tax

Personal and employment tax

Introduction

The commentary below discusses relief available for interest paid by personal representatives where they take out a loan to pay the inheritance tax liability of the estate. This should be read in conjunction with E1.820, which includes details about general restrictions that apply to all qualifying loans and the mechanism by which relief is given.

Loan to pay inheritance tax

Interest is eligible for relief if it is on a loan to personal representatives which is used¹:

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D6.503 International movement of capital—reportable transactions and events

E5.607 Corporate members

E4.507S Operation of the charge on securities with artificially enhanced market value

B3.325 General exclusions—first-year qualifying expenditure

C2.1020 Employment-related securities options and capital gains

I3.750 POAT—introduction to existing arrangements

B5.123 BPS—negligible value claims

A1.810 Limitation

I5.226 Disposals of QIIPs for consideration

B5.820 Charity's profits of trade—general liability to income tax

I5.251 Absolute entitlement by the life tenant

C2.1231 Leases—deemed premiums

C3.304 Rollover relief—expenditure on replacement assets qualifying for relief

B2.319 Duality of purpose—apportionment of the expenditure

D3.410 Benefits provided by close companies to participators

C3.1713 PPR relief where a dependent relative occupied the residence prior to 6 April 1988

C2.106 Deferred and contingent consideration on disposals

C2.1173 Interaction of the exemption election regime with other capital gains exemptions

E3.192 CGT loss relief on disposal of EIS shares

D4.412 CFCs—excluded territories exemption