offshore company-S455

[Chanmuganathan]

Hi

Offshore companies are subject to corporation tax for the last couple of years.

Question: Is S455 applicable, if the shareholder's loan is overdrawn? all shareholders are non-residents.

[wamstax]

Yes it would in my view apply if the individual(s) each had a material interest in the company and were not excepted by virtue of S456 CTA 2010,

See https://www.legislation.gov.uk/ukpga/2010/4/section/456