Commentary

D3.401 Outline of the key implications of close company status

Corporate tax
Corporate tax | Commentary

D3.401 Outline of the key implications of close company status

Corporate tax | Commentary

Division D3.4     Implications of close company status

For updates affecting this Division please see Part D0 Updates

Implications of close company status—overview

D3.401 Outline of the key implications of close company status

Due to the potentially very limited ownership and control of companies that are close, there are several targeted anti-avoidance provisions aimed at preventing manipulation of the tax rules. The fundamental aim of all these provisions is to prevent participators enjoying the use of the income of a close company free of tax, so special rules apply if:

  1.  

    •     a close company makes a loan/advance to a participator — there

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