Hi there,
Could anybody please give me their views on the following.
A company is to lend £2.4 million to a director for 20 years fixed and interest at the current HMRC official rate, again fixed which at this year is 4.75.
In view of section 177 17.19 may we assume that no benefit in kind would arise and that no tax would be assessed on the company under section 419.
The loan would be interest only and the full amount repayable at the termination of the agreement in 20 years.
I would be grateful for any feedback.
Many thanks.
PW
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