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HMRC internal manual

Company Taxation Manual

CTSA: Loans to participators: Quarterly instalments - credit or debit interest

CTA10/S458 relief can only affect credit or debit interest if the company is required to make quarterly instalment payments (see CTM92500 onwards) .

It can reduce the amount of the instalments payable if the loan is repaid, released or written off earlier than nine months and one day after the end of the accounting period in which it is made.

When relief is deferred by Section 458 (5), it cannot affect the amount of the quarterly instalment payments the company should have made for the accounting period in which the loan is made.