Making of loans to participators

For loans or advances made by a close company, a tax charge of 33.75% (32.5% before 2022/23) will apply if the loan was made otherwise than in the ordinary course of a business carried on by it, which includes the lending of money to any of the following:

1. •

   a person who is a ‘participator’ in the company or is an ‘associate’ of a participator

2. •

   a trust in which a participator or their associate is trustee or potential beneficiary, or

3. •

   an LLP or other partnership whose membership includes a participator or their associate ― this will catch, for instance, genuine