Loan to participators

Loan to participators

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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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By eastangliantaxadvisor
01st Mar 2013 20:07

I have no experiece of this in pratice, but my reading of CTM61515 is that there will no s455 charge

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