Section 419 - Loans to participators

A participator has an overdrawn loan account at the company year end. Within nine months this entire loan is repaid, but it is replaced by a new series of transactions creating a new overdrawn balance.

Is the original loan treated as being repaid and thus 419 relief is due when the CT return is filed? Or is the maximum relief available restricted to the new overdrawn balance?

Comments gratefully received!
Simon

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Postscript from New Enquiry Handbook published today

wdr |

Jay, I apologise on FA1998 s.24. but I stick to my guns on two p

wdr |

Reply to Red Queen

AnonymousUser |

We need to consider Relief under Loan Relationship Regulations a

AnonymousUser |

S 419 is a temporary problem

AnonymousUser |

Jay-how does the company recover the 419 payment if the loan is

wdr |

known to Revenue as "bed and breakfasting-they do not approve!!

wdr |

We aren't the only country to levy tax

Anonymous |

How Overdrawn?

DConlan |

What you need is a working model!

AnonymousUser |

We have done enough work on this and perhaps revisit it again!

AnonymousUser |