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HMRC internal manual

COTAX Manual

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HM Revenue & Customs
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Claims / reliefs: other reliefs: S458 CTA 2010 - loan repaid before due date

You may receive a completed form L2P, which is a form provided on the Government website for companies to claim relief. You must look at the information contained in the form to decide whether it should be treated as an amendment to the return, or a Sch1A claim.

Where the loan which gives rise to a liability under S455 is repaid, released or written off in full or in part before the normal due date (Word 49KB) of the AP in which the loan is made, the company can make a claim and give effect to the relief in the original return. Technically, there is a gross S455 liability for the period reduced or eliminated by S458 relief. See Example 2 (Word 48KB).

The CT600 company tax return allows a single entry of net S455 liability, which is captured onto COTAX. The detail of loans and repayments made are required on the CT600A supplementary page to the return. See COM53130 for more information.

The company has to complete the CT600A supplementary page if it makes loans within S458 during an AP. This asks for the details of:

  • loans made during the AP
  • the S458 tax chargeable on those loans
  • the amounts of those loans which have been repaid, released or written off
  • the S458 relief due
  • the net S455 liability.

The company has to show on the CT600 return form that it is required to complete the CT600A supplementary page.

The information in the CT600A is not captured onto COTAX and the CT600A does not contain details of loans made and reliefs given in earlier periods, or of unrelieved balances carried forward. So the CT600A does not itself allow you to keep track of the S455 position.

See:

  • COM53011 for a list of forms relevant to this subject
  • COM53013 for legislation applying to this subject.