Section 417 | Person liable
From legislation.gov.uk
(1)The person liable for any tax charged under this Chapter is—
(a)in the case of a loan or advance made to a partnership, any partner who is an individual, and
(b)in any other case, the person to whom the loan or advance was made.
(1A)If more than one person is liable in a case within subsection (1)(a), the liability is to be apportioned between them in a just and reasonable manner.
(2)This is subject to—
section 419 (loans and advances to persons who die), and
section 420 (loans and advances to trustees of trusts that have ended).