This, I think, falls into the too good to be true category, so please point out where I am wrong:
Major shareholders who have put money into trading company are higher rate payers. I think they fit all the qualifying heads in s392 ITA 2007 and are not excluded by ss393- 394. Shareholder has significant interst on personal loans.
Does not the interest fall to be relieved at higher rate, whereas if the company had borrowed CT relief would be at small company rate?