obviously a related party transaction per IAS24 which is unlikely to have been performed on commercial terms. (but may hqave been).
I think that your question really relates to whether or not this is actually a s419 case rather than a genuine loan.
As it's a partnership rather than another company, rather than write a long reply I'll guide you to section 17 of the expenses and benefits guide
http://www.hmrc.gov.uk/guidance/480_chapter17.pdf
You also need to read helpsheet 340
http://www.hmrc.gov.uk/helpsheets/hs340.pdf
Happy reading and hope that they help clarify the situation specific to your case but if not please bump the thread with more details as to the repayment arrangements, actual proximity of the partnership, etc. (are all of the directors also partners? are these really two seperate entities?),
kind regards,
Shaun.
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Shaun
Responses are not meant as a substitute for professional advice. Answers are intended as outline only the advice of a qualified professional with access to all relevant information should be sought before acting on any response given.
