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Use the Loans to participators template when a close company has loans, advances or arrangements that confer a benefit on a participator (or an associate of a participator) that are caught by Part 10 of the Corporation Tax Act 2010 (CTA 2010). The template calculates the tax charge due under s455 CTA 2010 on amounts outstanding at the period end, works out the relief due under s458 CTA 2010 where loans are repaid, released or written off, and feeds the resulting figures into the CT600 and the tax calculation.

Table of contents 

When should I use this template?

Use this template when the company is a close company and, during the accounting period, it made a loan or advance to a participator, or otherwise conferred a benefit through an arrangement caught by CTA 2010 Part 10, and some part of that loan or benefit remains outstanding.

A common example is an overdrawn director's loan account where the director is also a shareholder. The template also handles brought-forward balances from earlier periods and the relief that becomes due when those balances are later repaid, released or written off.

The template deals only with the company-level s455/s458 position. It does not calculate any personal tax (for example, a benefit-in-kind on a beneficial loan) for the participator.

What do I need before I start?

Make sure the UK Corporation Tax workflow has been added to the file and that the company has been correctly identified as a close company.

Because the tax rate depends on when each loan or benefit was conferred, have the following to hand for every participator:

  • The balance brought forward, split by the period in which it was originally conferred.
  • The movements in the current period (new loans, repayments, releases or write-offs).
  • The dates of any repayments, releases or write-offs, as the treatment differs depending on whether they happen within, or after, nine months of the period end.

How does the s455 charge work?

Under s455 CTA 2010, a close company that makes a loan or advance to a participator must pay tax equal to a percentage of any amount that is still outstanding nine months and one day after the end of the accounting period — the same date as the normal corporation tax payment date. If the loan is repaid in full before that date, no s455 charge arises.

The rate depends on the date the loan or benefit was conferred. Silverfin applies the following rates automatically based on the Period conferred you select for each row:

Period conferredRate
Pre 6 April 201625%
On or after 6 April 201632.5%
On or after 6 April 202233.75%

Where a loan is later repaid, released or written off, the company can reclaim the s455 tax under s458 CTA 2010. Relief cannot be claimed until nine months and one day after the end of the accounting period in which the repayment, release or write-off occurred, which is why the template splits repayments into those made within nine months of the period end and those made after.

Note on the 35.75% rate. At Budget 2025 the government announced that the s455 rate will increase from 33.75% to 35.75% for loans made, or benefits conferred, on or after 6 April 2026. The 35.75% rate will become selectable in Silverfin from 6 April 2027, in line with the update to HMRC's Corporation Tax online service. If the new rate applies to your company and you need to file before 6 April 2027, you will need to amend the return after 6 April 2027 to reflect the new rate. Where the period end is on or after 6 April 2026, Silverfin displays a reminder about this.

Step 1: Add the template and enter each participator

Add Loans to participators from the Corporation Tax workflow. Add a row for each participator or associate.

Enter each brought-forward balance on a separate row per period in which it was conferred. For example, if a single director has amounts conferred both pre 6 April 2016 and on or after 6 April 2022, enter those as two rows so that the correct rate is applied to each. Silverfin gives an on-screen reminder about splitting balances this way.

Step 2: Complete the main loans table

For each row, complete the movement columns:

  • Name of participator or associate – the person the loan or benefit relates to.
  • Period conferred – select the period in which the amount was originally conferred; this drives the tax rate.
  • Loan b/f – the balance brought forward.
  • Adjustment to b/f – any correction to the opening balance.
  • (Loan b/f repaid / released) – amounts of the brought-forward balance repaid or released in the period (entered as a negative).
  • Net additions – new loans or benefits conferred in the current period.
  • Loan c/f – calculated by Silverfin as the closing balance.

Silverfin shows a warning where a value has an unexpected sign — for example a negative loan brought forward, a positive figure in the repaid/released column, or a negative closing balance — so you can check the entry before finalising.

Step 3: Part 1 – Loans and arrangements made (the s455 charge)

Part 1 calculates the tax chargeable on loans and arrangements made in the period. For each participator with net additions, Silverfin shows the amount of the loan or benefit, applies the tax rate for the relevant period conferred, and calculates the tax chargeable.

Tick the box in Part 1 to confirm whether any or all of the loans made during the period were repaid, released or written off before the end of the period. Where the rate changed during the accounting period, the total tax chargeable is limited to total additions multiplied by the highest applicable rate, and Silverfin flags this with an on-screen note.

The total tax chargeable in Part 1 is the s455 charge and feeds box A20 of the CT600.

Step 4: Part 2 – Amounts repaid, released or written off within 9 months

Part 2 deals with amounts repaid, released or written off within nine months of the period end. For each participator, enter the amount repaid and/or the amount released or written off, together with the date. Silverfin calculates the tax relief due at the rate applicable to the original loan and checks that the date entered falls within the nine-month window, warning you if it does not.

The relief calculated in Part 2 feeds box A45 of the CT600.

Step 5: Part 3 – Amounts repaid, released or written off after 9 months

Part 3 deals with amounts repaid, released or written off more than nine months after the period end. Most companies will not need to complete Part 3 — see the CT600 guide for when it applies. Enter the amounts and dates in the same way as Part 2; Silverfin calculates the relief and checks the date falls after the nine-month window.

The relief calculated in Part 3 feeds box A70 of the CT600.

Where relief is due on the repayment of a brought-forward balance, Silverfin also calculates the tax (repayable) under CTA 2010 s458. Note that s458 relief cannot be claimed on the CT600 for the current return period; the repayment claim must be made in accordance with HMRC's internal guidance at COM53120.

What flows through to the rest of Corporation Tax?

  • The tax chargeable in Part 1 flows to box A20 of the CT600 and into the overall tax calculation.
  • The relief due in Part 2 flows to box A45, and the relief in Part 3 flows to box A70.
  • The s458 tax repayable figure is shown for information and is claimed separately, outside the current return.

For a long period of account, the template splits the analysis across the two accounting periods and shows a separate table for each, so the charge and relief are calculated correctly for each period.

What rolls forward next year?

The closing loan balance (Loan c/f) for each participator becomes next year's Loan b/f, retaining the period-conferred split so the correct rate continues to apply. Current-period movement fields — net additions, repayments, releases and their dates — clear for the new year.

Frequently asked questions

Which rate does Silverfin apply?

The rate is set by the Period conferred selected for each row: 25% pre 6 April 2016, 32.5% on or after 6 April 2016, and 33.75% on or after 6 April 2022. The 35.75% rate for loans made on or after 6 April 2026 will be available to select from 6 April 2027.

Why can I not select the 35.75% rate yet?

HMRC's Corporation Tax online service will not be updated for the new rate until 6 April 2027, so the option is not yet available in Silverfin. If the higher rate applies and you must file before then, file at the current rate and amend after 6 April 2027.

A loan was repaid before the period end — is there still a charge?

No. The s455 charge only applies to amounts still outstanding nine months and one day after the period end. Amounts repaid before then do not give rise to a charge, but should still be reflected in the movement columns.

Why is my closing balance showing a warning?

Silverfin warns where a column contains an unexpected sign — for example a negative closing balance, or a positive figure in the repaid/released column. Check the signs of the amounts entered.

Does this template calculate the director's personal tax?

No. The template only calculates the company's s455/s458 position. Any personal tax consequences for the participator are dealt with separately.