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Official guidance
Company Taxation Manual

CTM61500 · Close companies: loans to participators and arrangements conferring benefit on participator

  • CTM61505 · General
  • CTM61510 · Charging provisions
  • CTM61515 · Meaning of ‘relevant person’
  • CTM61520 · Partnerships
  • CTM61525 · Loans to trusts
  • CTM61530 · Close companies: loans to participators: business of lending money
  • CTM61535 · Close companies: loans to participators: extended meaning of loan: debts
  • CTM61537 · Close companies: loans to participators: unpaid share capital
  • CTM61540 · Close companies: loans to participators: exclusion of certain loans
  • CTM61545 · Close companies: loans to participators: material interest
  • CTM61550 · Close companies: loans to participators: indirect loans
  • CTM61555 · Close companies: loans to participators: indirect loans: total income
  • CTM61558 · Close companies: Loans to participators: liquidations and dissolutions: general
  • CTM61559 · Close companies: Loans to participators: Members Voluntary Liquidations (MVL)
  • CTM61560 · Close companies: loans to participators: Insolvent liquidations and dissolutions
  • CTM61561 · Close companies: loans to participators: company insolvent and loan irrecoverable
  • CTM61565 · Close companies: loans to participators: aggregating accounts
  • CTM61570 · Close companies: arrangements conferring benefit on participators: TAAR: arrangements to which a close company becomes party on or after 20 March 2013
  • CTM61575 · Close companies: arrangements conferring benefit on participators: TAAR: tax avoidance arrangements
  • CTM61580 · Close companies: arrangements conferring benefit on participators: TAAR: benefit conferred
  • CTM61585 · Close companies: arrangements conferring benefit on participators: TAAR: benefit conferred: partnerships
  • CTM61600 · Close companies: loans to participators and arrangements conferring benefit on participators: repayment of - general
  • CTM61602 · Close companies: loans to participators and arrangements conferring benefit on participators: repayment of – repayment actually made?
  • CTM61604 · Close companies: loans to participators and arrangements conferring benefit on participators: repayment of - transfers of assets
  • CTM61605 · Close companies: loans to participators and arrangements conferring benefit on participators: Repayment of- assignment/novation
  • CTM61610 · Close companies: loans to participators and arrangements conferring benefit on participators: repayment of - date relief is due
  • CTM61615 · Close companies: loans to participators and arrangements conferring benefit on participators: repayment of - bed and breakfasting - general
  • CTM61620 · B&B -repayments made up to 19 March 2013
  • CTM61625 · Close companies: loans to participators and arrangements conferring benefit on participators: B&B - repayments made on or after 20 March 2013 and return payments made before 30 October 2024: general
  • CTM61630 · Close companies: loans to participators and arrangements conferring benefit on participators: B&B: 30 day rule
  • CTM61635 · Close companies: loans to participators and arrangements conferring benefit on participators: B&B: arrangements rule:
  • CTM61640 · Close companies: loans to participators and arrangements conferring benefit on participators: B&B repeated loans/repayments
  • CTM61642 · Close companies: loans to participators and arrangements conferring benefit on participators: B&B - Exclusions
  • CTM61645 · Close companies: loans to participators and arrangements conferring benefit on participators: B&B operation of S464ZA - flowchart
  • CTM61646 · Close companies: loans to participators and arrangements conferring benefit on participators: B&B operation of S464ZA- table
  • CTM61650 · Close companies: loans to participators and arrangements conferring benefit on participators: repayment of - claims for relief
  • CTM61655 · Close companies: loans to participators: release or writing-off of loan or advance
  • CTM61657 · Close companies: Loans to participators: release or writing-off of loan or advance while temporarily non-resident
  • CTM61660 · Close companies: loans to participators: release or writing off of loan or advance: Class 1 NIC
  • CTM61665 · Close companies: loans to participators: death of recipient
  • CTM61670 · Close companies: loans to participators: termination of a trust
  • CTM61700 · Close companies: loans to participators: by controlled companies
  • CTM61710 · Close companies: loans to participators: companies controlled by a close company
  • CTM61720 · Close companies: loans to participators: acquisition of control of company
  • CTM61730 · Close companies: loans to participators: two or more close companies
  • CTM61740 · Close companies: loans to participators: arrangements not caught
  • CTM61750 · Close companies: loans to participators: treating loan as made by another company
  • CTM61760 · Close companies: loans to participators and arrangements conferring benefit on participators: referrals for unusual schemes
  • CTM61790 · Assessments
  • CTM61587 · Close companies: arrangements conferring benefits on participators: TAAR: benefit conferred: partnerships: interaction CTA10/S464A and mixed member rules S850C/ITTOIA05
  1. Close companies: loans to participators and arrangements conferring benefit on participator: contents
  2. Close companies: loans to participators: death of recipient

CTM61665 | Close companies: loans to participators: death of recipient

From HM Revenue & Customs · Company Taxation Manual

If you find a case where the company releases or writes off a loan or advance assessable under CTA10/S455 (CTM61510) and the individual to whom the loan was made has died, take the action below.

The guidance at CTM61655 should be applied to the person from whom the loan or advance is due at the time of the release or writing-off.

Officers should send a report to RIS Referrals, available via RIS A to Z, showing:

  • the full name and last address of the person to whom the loan etc was made and the date of his or her death,

  • the full name and address of the person from whom the loan etc was due at the date it was released or written off,

  • whether or not the loan etc is due from the person as personal representative (defined for this purpose in ITA07/S989) of the person to whom the loan was made,

  • the date the loan etc was released or written off and the amount released or written off,

  • the name of the company which made the loan or advance

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