CTM61730 | Close companies: loans to participators: two or more close companies

From HM Revenue & Customs · Company Taxation Manual

Two or more close companies may together control a company making a loan within or ( or ). In that case each close company is to be treated for the purpose of as:

  • controlling the lending company

  • making a loan of the appropriate proportion of the loan made by that company

When deciding what is ‘appropriate’, you should consider the nature and amount of the close companies’ respective interests in the lending company.