CTM61700 | Close companies: loans to participators: by controlled companies
From HM Revenue & Customs · Company Taxation Manual
brings certain loans not otherwise chargeable within and .
The loans affected are loans made under arrangements in which:
a loan is made by a third party to a close company participator or associate of a participator
and
the close company effectively finances the making of the loan.
Such arrangements normally involve the close company having or acquiring control of the lender. As such, the application of is limited to loans made to participators in a close company (or their associates) by a company that is, or comes to be, under the control of the close company.
You should construe as one with . Any reference in Section 460 to a ‘loan’ includes an advance. Similarly, any reference to a company making a loan includes cases in which a company is, or if it were a close company would be, regarded as making a loan by virtue of .
The powers of information in () apply to just as they do to .