With all the publicity that has surrounded other parts of FA 2025 practitioners could be forgiven for having missed the changes to the loans to participators regime tucked away in s 81.
The rules: The ‘loans to participators’ rules in CTA 2010 Part 10 Chapter 3 target the extraction of value from close companies (broadly those controlled by five or fewer participators or whose participators are all directors) by way of loan rather than dividend. In summary the rules charge to tax loans or advances made to participators in close companies which remain outstanding more than nine months after the accounting period in which they are made. This is commonly known as the ‘s 455 charge’. The rate of tax is 33.75% and the tax is payable by the company. Relief is available where the loan or advance is repaid.
The regime also includes rules...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
With all the publicity that has surrounded other parts of FA 2025 practitioners could be forgiven for having missed the changes to the loans to participators regime tucked away in s 81.
The rules: The ‘loans to participators’ rules in CTA 2010 Part 10 Chapter 3 target the extraction of value from close companies (broadly those controlled by five or fewer participators or whose participators are all directors) by way of loan rather than dividend. In summary the rules charge to tax loans or advances made to participators in close companies which remain outstanding more than nine months after the accounting period in which they are made. This is commonly known as the ‘s 455 charge’. The rate of tax is 33.75% and the tax is payable by the company. Relief is available where the loan or advance is repaid.
The regime also includes rules...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
