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HMRC internal manual

Company Taxation Manual

Close companies: loans to participators: death of recipient

If you find a case where the company releases or writes off a loan or advance assessable under CTA10/S455 (CTM61510) and the individual to whom the loan was made has died, take the action below.

The guidance at CTM61655 should be applied to the person from whom the loan or advance is due at the time of the release or writing-off.

Officers should send a report to RIS Referrals, available via RIS A to Z, showing:

  • the full name and last address of the person to whom the loan etc was made and the date of his or her death,
  • the full name and address of the person from whom the loan etc was due at the date it was released or written off,
  • whether or not the loan etc is due from the person as personal representative (defined for this purpose in ITA07/S989) of the person to whom the loan was made,
  • the date the loan etc was released or written off and the amount released or written off,
  • the name of the company which made the loan or advance