S455 tax

Is Company A, a UK-incorporated entity fully owned by non-UK Company B, obligated to pay S455 tax on an outstanding loan provided to an individual who, although not a director or shareholder of Company A, holds shares in Company B? The loan remains unpaid beyond 9 months from the end of the financial year, and it's important to note that lending money is not the primary focus of Company A's operations.

Hi QQask,
Please see the below guidance regarding what constitutes a participator and the application of s455 tax:
CTM61500 - Close companies: loans to participators and arrangements conferring benefit on participator:
if you require further advice on this matter, please seek professional help through a financial advisor or accountant.
Thank you.