EIM26115 | The benefits code: beneficial loans: meaning of by reason of employment: exception where loan made by an individual
From HM Revenue & Customs · Employment Income Manual
Section 174(5)(a) ITEPA 2003
The exception explained in EIM26114 also applies to loans made by a person within the third bullet of EIM26113.
So it will apply where:
a loan is made by an individual who has a material interest in a close company or in another company or a partnership which controls such a company and
the loan is made to an employee whose employer is that close company or controls it or is controlled by it and
the loan was made in the normal course of the lender’s domestic, family or personal relationships.