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HMRC internal manual

Company Taxation Manual

Close companies: extended meaning of distribution: profits chargeable to CT

No deduction is allowable (either in computing income from any source or as a charge against total profits) for expenses incurred in providing benefits for participators or their associates, which come within the extended meaning of distributions for close companies (see CTA2009/S289 (formerly ICTA88/S337 (2)) and CTA2009/S1305 (formerly ICTA88/S337A (1) (a)).