What is Section 455 tax on directors loans?▾
Section 455 (formerly S419) is a tax charge that applies when a close company (typically a director-owned limited company) makes a loan to a participator (usually the director/shareholder) that remains outstanding 9 months and 1 day after the company year end. The company must pay a percentage of the outstanding loan amount to HMRC — 35.75% for loans advanced on or after 6 April 2026, and 33.75% for loans advanced on or before 5 April 2026.
When is S455 tax due to HMRC?▾
S455 tax is due 9 months and 1 day after the end of the corporation tax accounting period in which the loan was made. For example, if your year end is 31 March 2027, the S455 tax is due by 1 January 2028. This aligns with the corporation tax payment deadline.
Did the S455 rate change in 2026/27?▾
Yes. The S455 rate tracks the dividend upper rate, and the Autumn Budget 2025 raised that rate by two percentage points from 6 April 2026. So S455 is 35.75% on loans advanced on or after 6 April 2026, up from 33.75%. Importantly this is not a blanket increase: the charge is fixed by the rate in force when the loan was advanced, so a loan you already owed at 5 April 2026 stays at 33.75% even if it is still outstanding well into 2026/27. If you have drawn several advances at different times, each one is charged at the rate that applied on its own date, so work them out separately rather than applying one rate to the whole balance.
Can I get a refund of S455 tax?▾
Yes. If the director repays the loan to the company, HMRC will refund the S455 tax. Relief is not given on the repayment date: it becomes claimable 9 months and 1 day after the end of the accounting period in which the loan was repaid, released or written off. So a loan repaid in June 2026 by a company with a 31 March year end gives relief claimable from 1 January 2028. You must claim it on form L2P or the CT600A — it is not automatic.
What is the bed-and-breakfasting rule for directors loans?▾
The bed-and-breakfasting rules (from April 2013) prevent directors from repaying a loan just before the year end and then re-borrowing shortly after. Under the 30-day rule, if £5,000 or more is repaid and a new loan of £5,000 or more is drawn within 30 days, the repayment is matched against the new advance and S455 tax still applies. A separate rule catches repayments outside 30 days where £15,000 or more is outstanding and there were arrangements, or an intention, to re-borrow.
What is the benefit-in-kind (BIK) on a directors loan?▾
If a directors loan exceeds £10,000 at any point in the tax year and is interest-free (or below the official rate), the director is treated as receiving a taxable benefit in kind. The BIK is calculated as the official rate of interest (currently 3.75%) multiplied by the loan balance. This is reported on form P11D.
What is the official rate of interest for directors loans?▾
The official rate of interest for beneficial loans is 3.75% per annum from 6 April 2025, up from 2.25% in 2024/25. HMRC sets this rate and uses it to calculate the benefit-in-kind charge when a director borrows from their company at less than this rate. From 2025/26 HMRC may review the official rate quarterly rather than fixing it for the whole tax year, so check the rate in force for the period before you file a P11D.
How do I report a directors loan to HMRC?▾
Directors loans are reported in several ways: the loan balance appears on the company balance sheet and CT600 corporation tax return. If the loan is outstanding at year end, S455 tax is reported on form CT600A. Any benefit in kind is reported on the directors P11D and included in the companys Class 1A NIC calculation.
Can I write off a directors loan?▾
A company can write off a directors loan, but this has tax consequences. The written-off amount is treated as a distribution (like a dividend) taxed at dividend rates on the director. The company also owes Class 1 NIC (employers and employees) if the director is also an employee. S455 tax may still apply until the write-off date.
Is there a limit on how much a director can borrow?▾
There is no statutory limit on directors loans, but loans over £10,000 trigger the benefit-in-kind charge. Any loan still outstanding 9 months and 1 day after the year end triggers S455 tax. Large loans also create cash flow issues for the company and can attract HMRC scrutiny.
What happens if I do not repay the directors loan?▾
If the loan remains outstanding, the company pays S455 tax to HMRC at the rate in force when the loan was advanced — 35.75% from 6 April 2026, or 33.75% for earlier advances. The director also faces a BIK charge if the loan exceeds £10,000. If the loan is eventually written off, it is treated as a taxable distribution. HMRC may also investigate whether the loan is genuinely a loan or disguised remuneration.