Before April 2025, it was possible to reduce or extinguish a charge to tax under s455, Corporation Tax Act 2010 (CTA 2010) on a loan to a director by including an anticipated repayment of that loan when completing the company’s tax return. This may have resulted in a loss of tax in some circumstances. HMRC is contacting agents by email where a client’s company tax return may have included an anticipated repayment.  

The charge to tax 

A tax charge under s455, CTA 2010 may arise where:  

• a close company makes a loan to a participator during an accounting period; and
• the loan is not repaid within nine months of the end of that period.  

Most small and medium-sized companies, and many larger companies, are close companies. The term “participator” includes a person who owns shares in the company. Links to guidance on the application of the rules are provided below.    

The s455 tax liability may be reduced where part or all of the debt due to the company is repaid within nine months of the end of the period. The charge, and any claim for relief, must be included in supplementary pages CT600A to the company’s tax return.  

Relief for anticipated repayments 

For company tax returns submitted before April 2025, it was possible to claim relief for an anticipated repayment when completing the CT600A pages. This is a repayment that was expected to be made after the date the return was filed, but still within nine months of the end of the accounting period.  

From April 2025 onwards, HMRC has corrected its systems so that a repayment date that is in the future cannot be entered when a return is filed. 

There is the risk of a loss of tax where: 

• the anticipated repayment was not made in the amount, or on the date that was expected; and 
• the company has not amended its return to reflect this.  

Action required from agents 

HMRC is asking agents with clients whose tax returns have included anticipated repayments to: 

• email HMRC using the contact details given in the letter by 28 November 2025 for details of the relevant clients; 
• help those clients to amend their tax returns if necessary; and
• advise them to make a payment on account to HMRC if additional tax is due in order to reduce the interest payable.  

Further information 

Legislation 

• S455, Corporation Tax Act 2010: charge to tax in case of loan to participator 
• S458, Corporation Tax Act 2010: relief in case of repayment or release of loan 

HMRC’s company taxation manual 

• CTM60100 onwards: definitions of “close company” and “participator” 
• CTM61500 onwards: loans to participators