In N Powell v HMRC [2025] UKFTT 528 (TC) (9 May) the FTT dismissed the taxpayer’s appeal against a closure notice charging income tax under ITTOIA 2005 s 415 in respect of the release of a close company loan to a participator.
The taxpayer was a director and sole shareholder of T Ltd and had an overdrawn director’s loan account with the company so that the company was subject to a charge under CTA 2010 s 455. In 2020 following a share for share exchange T Ltd became a subsidiary of PHSW Ltd of which the taxpayer was also a director. The taxpayer T Ltd and PHSW Ltd entered into a novation of the outstanding loan account to transfer T Ltd’s rights to PHSW Ltd. T Ltd released the taxpayer from his obligations to it and PHSW Ltd acquired its rights...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
In N Powell v HMRC [2025] UKFTT 528 (TC) (9 May) the FTT dismissed the taxpayer’s appeal against a closure notice charging income tax under ITTOIA 2005 s 415 in respect of the release of a close company loan to a participator.
The taxpayer was a director and sole shareholder of T Ltd and had an overdrawn director’s loan account with the company so that the company was subject to a charge under CTA 2010 s 455. In 2020 following a share for share exchange T Ltd became a subsidiary of PHSW Ltd of which the taxpayer was also a director. The taxpayer T Ltd and PHSW Ltd entered into a novation of the outstanding loan account to transfer T Ltd’s rights to PHSW Ltd. T Ltd released the taxpayer from his obligations to it and PHSW Ltd acquired its rights...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
.tmb-editorspic.jpg?sfvrsn=c9a7a0cc_1)
