Q&A: inheritance tax and a director’s loan

In this week’s Q&A, Ibrahim Nalla ATT CTA, tax adviser at Croner-i VIP Tax Team, explains the inheritance tax implications of a director’s loan assignment, including chargeable transfers and chose in action rules

Our client is a director and the sole shareholder of a UK company and wants to know his inheritance tax (IHT) position ahead of the forthcoming changes to business property relief (BPR) in April 2026.

The client currently has a credit director’s loan account (loan) owing to him from the company and as part of IHT planning we want to consider the IHT implications of assigning the loan to his adult children. No interest is being charged by the client on the loan.

All references below are to Inheritance Tax Act 1984 (IHTA 1984) unless stated otherwise.

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