Revenue eBrief No. 034/25
06 February 2025
Company Charge to Income Tax on Loans to Participators
Tax and Duty Manual (TDM) Part 13-02-03 provides guidance on the close company provisions in section 438 TCA 1997, where a tax charge arises on the making of a loan to a participator of a close company.
The guidance within this TDM has been updated to include a new introduction, some additional information on the operation of the provisions and more examples.