Part 10Close companies
Chapter 3Charge to tax in case of loan to participator
Loan treated as made by close company
461Exception to section 460
(1)
Section 460 does not apply if it is shown that no person has made any arrangements (otherwise than in the ordinary course of a business carried on by the person) as a result of which there is a connection—
(a)
between—
(i)
the making of the loan or advance, and
(ii)
the acquisition of control, or
(b)
between—
(i)
the making of the loan or advance, and
(ii)
the provision by the close company of funds for C.
(2)
The close company is to be treated for the purposes of subsection (1) as providing funds for C if it directly or indirectly makes a payment or transfers property to, or releases or satisfies (in whole or in part) a liability of, C.