S455 arises on close co loans to participators. However HMRC manuals ( and indeed some articles) imply this is due on director loan accounts, not specifying participators. Not all directors are participators and if not participators (or associates of participators) I don't feel they are caught.
Am I missing a point here?
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No. You are not missing a point. Some people, including HMRC unfortunately, are too loose in their language.
A loan to a non-participating director may still have benefit in kind implications.
