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HMRC internal manual

COTAX Manual

Claims / reliefs: other reliefs: S458 CTA 2010 - interaction with penalties

The inclusion of S455 on loans to participators within the self assessment tax charge may affect the tax base for the calculation of any tax-related late filing penalty.

Where a close company is liable to tax under Section 455 CTA 2010 on loans or advances to a participator in the company and claims relief under S458 because a loan has been wholly or partly repaid, released or written-off, the relief may be deferred under S458(5) until the normal due date (Word 49KB) for the AP in which the repayment, release or write-off takes place.

The deferred relief is ignored in determining the amount of unpaid tax for the purposes of any tax-related penalty. For more information see.


  • COM100000 onwards for more information
  • COM53013 for legislation applying to this subject.