CTM61555 | Close companies: loans to participators: indirect loans: total income
From HM Revenue & Customs · Company Taxation Manual
A payment, transfer, release etc, arising from an arrangement described in may be included in the total income of the recipient of the payment.
When the amount included in that person’s total income is more than or equal to the amount of the loan or advance, will not apply.
This may happen, for example, where:
a payment to the recipient is treated as his/her income for IT purposes (for example, as a distribution within B or , or
a loan to the recipient falls within the provisions of
The ‘total income’ of an individual is defined in as the sum of the amounts of income on which the taxpayer is charged to income tax for the tax year. Broadly speaking it consists of earned and investment (or unearned) income. It does not include anything on which capital gains tax is or would be chargeable.