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Hi there, I have a few questions regarding the notion of directors' loans. All questions are about a director loaning money to a close LTD company incorporated in England and Wales. (1) Is there anything specific I should write in the bank transfer description/reference for the directors' loan, in case a director is funding the company with a zero interest loan, (a) in the bank transfer from the director to the company and (b) from the company back to the director? (2) Are directors' loans aimed at funding the company only available to directors of a LTD company or also to its shareholders? If not specifically available to shareholders, is a shareholder lending money to his/her company considered the same as a third party lending to the company? Is there any difference if the shareholder holds an interest in a trading company to which he is lending through the use of a holding company? (3) Directors' loans can be used to help with startup costs as an alternative to a share capital subscription. However, some startup costs could be born by the prospective director of a company that is still to be created, for the purposes of starting the company itself, before the company is incorporated formally. If a director personally bears costs that are logically and reasonably connected to the activity that the soon-to-be-incorporated LTD company will carry out, and this happens reasonably close to the date of incorporation, can these payments be considered a director's loan even if the company still doesn't exist? Examples could be the cost of website hosting, email, accounting/legal advice to set up the company and any reasonable cost that a director would incur as a function of his role. The need for this might arise, for instance and among other things, if for any reason the incorporation of the company is delayed but some costs have already been incurred. (4) Is a zero interest directors' loan from the director to the company (for startup costs) legitimate since it doesn't follow the usual "at arm's length" requirement for this kind of operation? Do you confirm it is not a benefit-in-kind (or similar) for the company? (5) Assume a director loaning money to his company wants to relieve the company (and therefore also any other director) from the risk of taking on the loan itself. He decides to write a note to the company (or a simple contract) where he agrees that if the company cannot at any point in good faith and reasonably repay the loan, any and all claims from the director towards the company and in relation to that loan become void. In other words he agrees that the loan is repayable only if and when the company can afford it. Is this (a) legitimate, and (b) does it have any implications as far as HMRC is concerned? Thanks a lot for your help

I'd like to understand the tax treatment for a certain type of personal income under the current non-dom (remittance basis) rules. Specifically whether (1) personal income in the form of a dividend arising from a UK trading company owned by an EU holding (non-trading) company, in turn owned by the non-domiciled UK resident, is considered foreign or UK income; and whether (2) personal income in the form of a dividend arising from a foreign (EU) trading company owned by a UK holding (non-trading) company, in turn owned by the non-domiciled UK resident would be considered UK or foreign income. To clarify, these are two mirror situations and in each case the dividend is distributed from the holding company which owns a majority stake (50% or more) of the trading company. Consider the holding company as a personal private limited company (so the new QAHC provisions do not apply). Assume all dividends to be paid to a non-UK bank account (therefore non-remitted if they are non-UK income in the first place). Please assume the shareholding in the UK trading company in case (1) to predate the remittance basis election by the taxpayer, so BIR would not apply (and is outside the scope of the question). In case (1) I would assume the payment to be UK income because even if the dividend is distributed from an overseas company to an overseas account, the value produced by the company is UK-related and the company profited from the UK economy. In case (2) it would seem odd to treat it as UK income given that the holding company does not carry out a business and does therefore not generate any income per se. Finally, in general terms what is the normative and policy basis for defining UK income under the remittance basis? Finally, is there any difference if the shareholding in the trading company is qualified vs unqualified, and what is the relevant threshold? Thank you for your help.