Corporation Tax � close company shareholders � anti-avoidance measure
This measure is about an amendment to ensure that the Targeted Anti-Avoidance Rule in the loans to participators legislation remains robust and effective against avoidance.
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ʹapp rules governing the charge on loans from close companies to, or benefits conferred on, their participators are found at Chapters 3, 3A and 3B of Part 10 Corporation Tax Act 2010 (CTA10). ʹapp purpose of this Loans to Participators regime is to deter companies from making untaxed loans to their participators or allowing them otherwise to extract company funds untaxed, rather than paying wages, dividends or other income chargeable to tax. ʹapp charge is on the close company at a current rate of 33.75% of any amounts outstanding 9 months after the end of the accounting period. ʹapp close company can claim relief for any s455 tax if the loan, other monies or value is repaid to the company.