EIM26160 – The benefits code: beneficial loans: exemption for commercial loans: meaning of substantial proportion
Section 176(3)(b) ITEPA 2003
For the purposes of exemption under Section 176(1) ITEPA 2003
(see
EIM26158 and
EIM26170), the substantial proportion
test operates by reference to numbers of loans and not by reference
to total amounts lent.
So if 50% or more of the comparable loans made at or about
the time when the employee loan was made or varied were made to
members of the public at large this test will be satisfied. Whether
a proportion below 50% would be enough will be a matter of fact and
degree.
(This text has been withheld because of exemptions in the
Freedom of Information Act 2000)
- (This text has been withheld because of exemptions in the Freedom of Information Act 2000)
- (This text has been withheld because of exemptions in the Freedom of Information Act 2000)
- (This text has been withheld because of exemptions in the Freedom of Information Act 2000)
- (This text has been withheld because of exemptions in the Freedom of Information Act 2000)
