Director’s loan was not written off or released on liquidation
In G Quillan v HMRC [2025] UKFTT 421 (TC) (10 April) the First-tier Tribunal (FTT) allowed the taxpayer’s appeal finding that his director loan account balance was neither written off nor released for the purposes of ITTOIA 2005 s 415(1) on the liquidation of the company contrary to HMRC’s guidance in their Company Taxation Manual.
The taxpayer was the sole director of a company which went into voluntary winding up and a liquidator was appointed. At that time the director’s loan account with the company was overdrawn in the amount of £439 954. The liquidator demanded payment and the director advising that he did not have the means to pay and after much correspondence offered to pay £57 500 to settle the claim. This amount was paid in instalments and the liquidator’s report...
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Director’s loan was not written off or released on liquidation
In G Quillan v HMRC [2025] UKFTT 421 (TC) (10 April) the First-tier Tribunal (FTT) allowed the taxpayer’s appeal finding that his director loan account balance was neither written off nor released for the purposes of ITTOIA 2005 s 415(1) on the liquidation of the company contrary to HMRC’s guidance in their Company Taxation Manual.
The taxpayer was the sole director of a company which went into voluntary winding up and a liquidator was appointed. At that time the director’s loan account with the company was overdrawn in the amount of £439 954. The liquidator demanded payment and the director advising that he did not have the means to pay and after much correspondence offered to pay £57 500 to settle the claim. This amount was paid in instalments and the liquidator’s report...
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