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HMRC internal manual

Employment Income Manual

The benefits code: beneficial loans: exemption for commercial loans: meaning of at or about the time

Section 176(3) ITEPA 2003The exemption under Section 176(1) (see

EIM26158) requires that comparable loans (see EIM26159) or relevant loans (see EIM26175) are made or held at or about the time the loan was made or varied to the employee.

The legislation does not specify the timespan within which the loans to be taken into account have to be made. It is simply a matter of applying common sense. If a public offer for loans for the same or similar purposes and on particular terms and conditions is open from 1 April to 31 December all such loans made in that period will have been made at or about the same time for the purposes of the substantial proportion test.