Not sure if you have read my post correctly as the Capital gains and Loan repayment are different issues. If her loans are repaid as others have suggested, it is the club that repay them unless she writes them off. She would not wish to convert them to equity as she did before, as I suspect this would fall foul of the deal with the Chinese. Whilst interest on the Loans are not normally tax free, I agree the capital repayments are. However, as you say I expect some accountant has sewn this up with Trusts and offshore Tax status.