The exemption under Section 176(1) (see
EIM26158) requires that comparable loans
(see
EIM26159) or relevant loans (see
EIM26175) are made or held at or about
the time the loan was made or varied to the employee.
The legislation does not specify the timespan within which
the loans to be taken into account have to be made. It is simply a
matter of applying common sense. If a public offer for loans for
the same or similar purposes and on particular terms and conditions
is open from 1 April to 31 December all such loans made in that
period will have been made at or about the same time for the
purposes of the substantial proportion test.
