HMRC’s guidance on home loan schemes

KEY POINTS

• HMRC considers all home loan schemes are ineffective.
• Guidance explains how the Revenue might settle schemes at various stages of their life.
• The disclosure of tax avoidance schemes regime now applies to inheritance tax.
• Home loan schemes fall within the hallmarks.

The saga of home loan schemes also known as double trust schemes has had a further development. HMRC has issued guidance setting out how it will settle cases in advance of a judicial decision. No case has yet determined either the success or in the current climate the increasingly likely failure of these schemes.

What was the mischief?

Home loan schemes were targeted at taxpayers whose estates exceeded the nil-rate band and in which property formed a substantial part. The schemes sought to remove...