Page 34 - Chapters 17 & 18 - Dividends & Dividend Tax
P. 34

Loan To s/h







                           Loan to the holder of a share will be a deemed

                                                     dividend in specie if:



              • Requirements:

              • Person owes an amount in respect of a debt                                                        ≥ 20% of equity

                                                                                                                     shares and
              • Person must be a resident                                                                           voting rights

              • Person may not be a company

              • Person must be a connected person of the company OR

                   a connected person in relation to a connected person
                   of the company


              • Debt must be provided by virtue of a share held in the

                   company (because the person holds shares in a specific co,
                   he qualifies to take a loan from the co)




                                                          Deemed dividend

                                                                in specie
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