Holding Company (WHL), dormant since 1995, inherited a Loan/Creditor balance of £2,200 to an associated Property Partnership (Partners also Directors of WHL). At the time the Property Partnership had no trading revenue and so, naively, the O/S value was reported as Private Investment for WHL BS control purposes. WHL had Dormant Status until 2016, when CT Return was due against Interest Received. HMRC have charged Tax Due of 32.5% as Loan to Participators. Strictly, this was only a Trade Creditor, although Payment Due Date had not been foretold. This will be immediately repaid! What form should an Appeal against the whole charge be made, please. Happy to send full details to you by email.’
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