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S.455 tax on loans to parent company?

Never heard about this until today

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Just reading the legislation on s.455 tax and it is worded in a way that includes a loan from a subsidiary to parent company in a close company group.

Am I understanding that correctly? So if a sub has no reserves and lends money to a parent, this will trigger s.455 tax? 

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By Wanderer
10th Dec 2021 11:33

How are you interpreting S455 that way?

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By SteveHa
10th Dec 2021 11:40

I suspect misinterpreting S455(4) and (5)

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Replying to SteveHa:
RLI
By lionofludesch
10th Dec 2021 11:43

SteveHa wrote:

I suspect misinterpreting S455(4) and (5)

In particular, ss 5.

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By Paul Crowley
10th Dec 2021 12:52

There is confusion on circular loans, so that S455 is not avoided by passing loans around in a company group or associated company where borrower is not a shareholder of eventual lender, but was from company that started the circle

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