RFIG21610 | Statutory Residence Test (SRT): Temporary non-residence: Loans to participators released or written off

If an individual has received a loan or an advance from a company and that loan or advance is released or written off while they are temporarily non-resident a charge arises at that time, regardless of whether they are UK resident.

However, this charge may be removed under the terms of double taxation agreements between the UK and the country in which they are temporarily resident. When the original charge is removed under these conditions, a new liability will arise on the period of their return. See CTM61657 for more information.