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HMRC internal manual

Company Taxation Manual

Close companies: loans to participators and arrangements conferring benefit on participators: referrals for unusual schemes

It is not expected that schemes on the lines described in CTM61700 and CTM61710 will continue to be used. Nevertheless, where you find:

  • a scheme with similar intentions which appears to escape both CTA10/S455 and CTA10/S460 or
  • a close company’s acquisition of shares or provision of funds appears to have facilitated a loan to the close company participator, yet the company claims that the arrangements are not within those described in CTA10/S461 (CTM61730)

you should send a submission with the file to CTIS (Technical).

Equally, CTIS Technical will be interested to hear of any schemes/arrangements which purport to avoid CTA10/S455, CTA10/S459 or CTA10/S464A or to effect repayments with the participator having to pay little or anything over to the company.