D3.410 Benefits provided by close companies to participators
Special rules apply to tax benefits provided by a close company to a participator. The general rule taxes certain benefits in kind and is discussed below. However if the general rule does not apply but value has been extracted from the company through tax avoidance arrangements, the targeted anti-avoidance rule may well apply; see 'Benefits provided to a participator—tax avoidance arrangements' below.
Benefits provided to a participator—general rule
Where a close company provides a benefit to a participator, that is not specifically excluded (see below), the implications for the company and the individual concerned are1:
- Ìý
•ÌýÌýÌýÌý company – treated as making a distribution equal to the expense of providing the benefit, less any part of the expense made good by the participator
- Ìý
•ÌýÌýÌýÌý individual – treated as receiving a dividend and taxed accordingly
A reference to a participator includes an associate (see D3.103), and any participator in a company which controls another company is treated as being also a participator
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Web page updated on 24 Aug 2024 14:48