Page 33 - P6 Slide Taxation - Lecture Day 4
P. 33
LOAN TO S/H
Loan to the holder of a share will be a deemed
dividend in specie if:
Requirements:
≥ 20% of
• Person owes an amount in respect of a debt 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
