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HMRC internal manual

Employment Income Manual

HM Revenue & Customs
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The benefits code: beneficial loans: calculation of chargeable benefit: aggregation of loans between same lender and borrower

Section 187 ITEPA 2003The legislation provides for certain loans to be aggregated when calculating the cash equivalent. Only certain loans to directors may be aggregated.

The normal rule is that each loan is dealt with as a separate loan, unless:
* the lender in respect of two or more loans that are outstanding at the same time is a close company (see EIM26500) and the borrower is a director of the company and * the company elects (see EIM26192) by 6 July following the end of the tax year for aggregable loans (see EIM26190) to be treated as single loans.