CTM61750 - Close companies: loans to participators: submissions to Head Office

It is not expected that schemes on the lines described in CTM61700 and CTM61710 will continue to be used. Nevertheless, where you find:

• a scheme with similar intentions which appears to escape both ICTA88/S419 and ICTA88/S422; or
• a close company's acquisition of shares or provision of funds appears to have facilitated a loan to the close company participator, yet the company claims that the arrangements are not within those described in ICTA88/S422 (4) (CTM61730),

you should send a submission with the file to CTIAA (Technical).