Husband & wife own Parent company which owns 100% shares in company A.
Husband & wife also own 100% shares in company B.
Company A & B carry out unrellted trades but do sell goods to one another.
Company A has surplus cash & is able to loan money to B to finance the purchase of equip >£1m rather than B getting external finance.
Am I correct in thinking that as the companies are under common control taht the loan would be taxed as if made to the directors? Company A is not in the business of making loans the only reason it is making the loan is beacuse of the common control?
If company B paid interest at market rate this would eleminate BIK on directors but company A would still have to CT on the outstanding balance 9 months after YE?