CTM61090 - Close companies: capital payments to settlors: temporary loans
Certain temporary loans or temporary loan repayments made by a close company connected with the settlement to a settlor or settlor바카라 사이트™s spouse are taken out of the scope of ITTOIA/S641 and hence ITTOIA/S633 by ITTOIA/S642.
The type of loan that can be excluded is one made:
- to the settlor or his or her spouse,
- by the close company, or another close company, connected with the settlement, or
- by the settlor or spouse to that or any other close company connected with the settlement.
To be excluded:
- the whole of the loan must be repaid within twelve months of the date on which it is made, and,
- the period for which loans are made must not exceed twelve months in any period of five years.
Repeated 바카라 사이트˜temporary바카라 사이트™ loans will thus, in general, continue to be caught by Section 633 (subject to CTM61130).