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HMRC internal manual

Company Taxation Manual

From
HM Revenue & Customs
Updated
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Close companies: loans to participators: termination of a trust

In cases where a loan or advance assessable under CTA10/S455 (CTM61510) was made to trustees and the trust comes to an end before the company releases or writes off the loan etc, take the action below:

The instruction 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 also report the following information to RIS Referrals, available via RIS A to Z:

  • The full names and addresses of the trustees to whom the loan or advance was made and the date the trust came to an end
  • Any information you hold about the trust
  • The full name and address of the person from whom the loan or advance was due at the date it was released or written off
  • 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