Am I right in thinking that if an LLP is set up where there are three partners, one is a close company and the other two are directors/shareholders of the close company and the close company lends money to the LLP so it can operate then:
1) There is no S.455 CTA 2010 liability following CTM61515
2) There is no beneficial loan arrangement as the loan is for a qualifying purpose
Does anyone have experience of this type of arrangement?
Thank you for your help
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I have no experiece of this in pratice, but my reading of CTM61515 is that there will no s455 charge