Are undrawn profits a "loan" for s455 purposes?

following on from a recent post along the same lines.

Corporate partner is allocated a share of revenue profits but doesn't receive them in cash terms.  This current account with the partnership is shown in the company accounts as a debtor.  The cash is annual drawn down by the individual partner, who controls the company.

The partnership is not a genuine scottish partnership therefore this http://www.hmrc.gov.uk/manuals/ctmanual/CTM61515.htm wont apply..

Q, would s455 apply?

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I don't think so

George Attazder |
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I'd say no

BKD |
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Blimey!

George Attazder |
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Now, now, George

BKD |
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.

blok |
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Rationale

BKD |
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Careful...

George Attazder |
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No, no, no

George Attazder |
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Agreed

BKD |
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going out on a limb....

zeofiles |

Well, as I (and BKD) have said above

George Attazder |
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Another way of looking at it

BKD |
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I don't think that you

Triggle |

s455 may be due if

johnt27 |

Contradictory

BKD |
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Eh?

George Attazder |
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Aha!

George Attazder |
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confused.com #1

zeofiles |

.

blok |
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.

blok |
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@blok

George Attazder |
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As an example

zeofiles |

Section numbers were so last year....

johnt27 |

Assets

BKD |
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To reply to zeofiles' example

BKD |
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But if a drawing was made by

Triggle |

Yes, Triggle

BKD |
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@triggle

zeofiles |

Taxable income

BKD |
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As an aside ...

BKD |
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*

Triggle |

@ BKD, sorry think i have

zeofiles |

.

blok |
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.

blok |
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PA 1890

George Attazder |
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Scottish or not

BKD |
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.

blok |
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Care to elaborate?

BKD |
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.

blok |
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.

blok |
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Apologies for labouring the point

BKD |
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.

blok |
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I think it is a red herring, because ...

BKD |
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Yes but...

George Attazder |
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.

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