136U.K.In Chapter 6 (release of loan to participator in close company), after section 420 insert—
(1)This section applies if an individual is temporarily non-resident.
(2)Debts within subsection (3) are to be treated for the purposes of this Chapter as if they had been released or written off in the period of return.
(3)A debt is within this subsection if—
(a)it is the debt, or a part of the debt, in respect of a loan or advance made by a company to the individual,
(b)it is released or written off in the temporary period of non-residence, and
(c)ignoring this section, the individual—
(i)is not liable for tax under this Chapter in respect of the release or write-off, but
(ii)would have been so liable, had the release or write-off taken place in the period of return.
(4)Subsection (3)(c)(i) includes a case where the individual could be relieved of liability on the making of a claim under section 6 of TIOPA 2010 (double taxation relief), even if no claim is in fact made.”