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Deemed Gift Loan

Deemed Gift Loan

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The company I work for is doing a reorganisation of its loans.

Entity A Controls Entity B controls Entity C.

Entity A is the lender and entity C is the receive of a covered loan. The debt relates to ordinary trading.

Now Entity A will transfer the loan to Entity B as a deemed gift?

Would this give rise to any tax charge. Does value shifting rules apply.

 

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By johngroganjga
16th Dec 2020 16:16

What is a “covered” loan?

What is a “deemed” gift? Is it the same as an actual gift?

Why does A want to gift its receivable to B?

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Replying to johngroganjga:
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By The Dullard
16th Dec 2020 16:23

Why are you asking these questions? Do you just want to blow Anonymous's cover?

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By Tax Dragon
16th Dec 2020 17:35

At the moment it's the relevant taxes acts that are anonymous. What sort(s) of "entity"?

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By Duggimon
17th Dec 2020 14:33

I'm going with grandfather > father > son

In which case it's all non-taxable, job done.

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By johngroganjga
16th Dec 2020 16:16

.

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