Elborne v HMRC: What the Court of Appeal decision means for practitioners
Overview The England and Wales Court of Appeal’s decision in Elborne v HMRC [2026] EWCA Civ 894 has confirmed that the inheritance tax (IHT) planning arrangement, commonly referred to as a ‘home loan’ or ’double trust’ scheme, succeeded on its specific facts. The Court unanimously dismissed HMRC’s appeal, concluding that the statutory provisions relied upon… Read More Elborne v HMRC: What the Court of Appeal decision means for practitioners










