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HMRC internal manual

Employment Income Manual

The benefits code: beneficial loans: calculation of chargeable benefit: aggregation of loans: continued

Section 187 ITEPA 2003

An election (see EIM26192) can be made for certain loans made by a close company to one of its directors to be aggregated. This overrides the usual rule (see EIM26180) that loans are not aggregated for those years.

These aggregable loans are:

  • made between the same lender and borrower and
  • beneficial loans (that is, at no time in the year is a rate of interest applied that is equal to, or greater than, the official rate) and
  • not qualifying loans (qualifying loans (see EIM26137) cannot be aggregated) and
  • in the same currency.