by AliNic on Tue Jan 03, 2012 11:04 am
Happy new year!
A question about interest deductibility in a close company.
A friend of mine is proposing to set up his own Ltd Co to buy the shares he owns in 2 trading co's, an IT & marketing services to property sector, and an estate agency.
The shares will be purchased at fair value and the purchase financed by a bank loan to the Ltd Co - ie he is effectively mortgaging the shares he already holds
The Ltd Co will also employ him and invoice these 2 companies for his services as director
As far as I can make out from hmrc's contorted definition, the Ltd Co will be regarded as a close investment holding co
Will the bank interest payable by the Ltd Co be allowable for corporation tax purposes? Any other comments on the above arrangement would be much appreciated
Many thanks