"A loan to a beneficiary is not an emolument. It is simply an investment made by the EBT. At some point the loan will have to be repaid and the money will then be available to the trustee to disburse in line with the terms of the trust (which is likely to be in the form of emoluments)."
Not my words, but HMRC's. Thus it shows HMRC's view that such loans were always taxable as nonsense.