This part of GOV.UK is being rebuilt – find out what beta means

HMRC internal manual

Company Taxation Manual

Close companies: loans to participators: two or more close companies


Two or more close companies may together control a company making a loan within CTA10/S460 (1) or CTA10/S460 (3) (CTM61700 or CTM61710). In that case each close company is to be treated for the purpose of CTA10/S460 as:

  • controlling the lending company
  • making a loan of the appropriate proportion of the loan made by that company

When deciding what is ‘appropriate’, you should consider the nature and amount of the close companies’ respective interests in the lending company.