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Posted Fri, 10 Nov 2023 15:24:27 GMT by
Hi, I just moved to the UK 4 months ago and will likely stay here for good. In order to continue with my consulting business, I have set up a new limited company here in the UK as sole shareholder and Director. To run the business and pay related business expenses here in the UK, I will need to transfer some money from my previous country of residence, where I stayed for in the past 40+ years. I understand there is no tax implication, please correct me if I am wrong, when I transfer the money (the loan, free of interest) into my UK limited company. As my business grows and is able to self sustain financially, the loan will need to be repaid back to me, free of interest. I would like to understand if there is tax implication when the loan is being repaid back to me into my UK bank account.
Posted Thu, 16 Nov 2023 15:33:22 GMT by HMRC Admin 13
Hi This question cannot be answered by HMRC. We suggest that you contact a tax adviser or accountant for information about loans to the company and any tax implications. Thank you
Posted Thu, 16 Nov 2023 19:18:39 GMT by
Maybe the questions was not being asked properly. Let me rephrase it in order to understand the relevant tax rules. Can you provide the tax rules on Director's loan to the company, when it is being paid and repaid. What are the tax rules for monies remitted into the UK from other countries as a loan and when it is remitted back to the loan provider. Many thanks!
Posted Tue, 21 Nov 2023 13:14:24 GMT by HMRC Admin 8
The question is unclear. If this is a loan from  the company to a  director, Legislation in relation to loans to participators can be found from S455 CTA2010 onwards.  If it is a loan to the company, there is no corporation tax implications.However, you may be liable for income tax on any interest received on the loan.
Thank you.
Posted Tue, 21 Nov 2023 13:41:04 GMT by
The loan is from the Director to the Company. It is remitted from outside of UK into the company's bank account, for this part I understand there is no tax implication. However, the reality is the Director is a UK tax resident and he has chosen remittance basis for his worldwide income. The question is, since the loan is remitted from outside UK and later when it is due for repayment, is repaid to the Director's UK bank account, will this be considered in HMRC's view that the money remitted is taxable, whether at the point when the loan arrives in the UK Company bank account, or at the point when it is repaid to the Director.
Posted Wed, 22 Nov 2023 17:31:04 GMT by HMRC Admin 25
Hi wcky1979,
Please refer to:
Remittance basis 2023 (HS264)
Thank you. 

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