477. Loans by company controlled by close company.

Where a company1 which is controlled2 by a close company3 makes a loan4 which does not otherwise give rise5 to a charge to tax, the statutory provisions relating to loans6 to participators7 apply as if the loan had been made by the close company8; and, where a company which is not controlled by a close company makes such a loan and a close company subsequently acquires control of the company, those provisions apply as if the loan had been made by the close company immediately after the time when it acquired control9.

Where two or more close companies together control