CTM60660 | Close companies: extended meaning of distribution: payments to participators
From HM Revenue & Customs · Company Taxation Manual
The extended meaning of distribution should be regarded as applicable to money benefits (for example, gifts of money) for participators and their associates, which are not made good to the company.
It should also be applied to benefits in kind, in so far as such payments are not already distributions within onwards. But the application of the extended meaning may be precluded by (directors and employees), (groups of companies), (distributions in a winding-up), or (covenanted donation to a charity).