We have a client who trades as a Limited Company. He's looking to raise a loan within the company to help a family member (brother) set up his own business.
I understand that under the S455 rules a loan to an "associate" is caught but a couple of other options I'd like a second opinion on:
1, loan to associate's partner
2, loan to a partnership (her brother and partner are considering setting up the business as a partnership)
3, loan to a limited company - if our client was involved. Thinking of this being treated as inter-company. What would the involvement of our client need to be in this company for it to be treated as inter-company. % shareholding? Directorship?