{
  "url": "https://openlegislation.uk/finance-act-2013/schedule-45/paragraph-136",
  "json_url": "https://openlegislation.uk/finance-act-2013/schedule-45/paragraph-136.json",
  "legislation": "ukpga/2013/29",
  "legislation_title": "Finance Act 2013",
  "legislation_url": "https://openlegislation.uk/finance-act-2013",
  "path": "schedule/45/paragraph/136",
  "kind": "paragraph",
  "number": "136",
  "heading": null,
  "text": "In Chapter 6 (release of loan to participator in close company), after section 420 insert—\n“Temporary non-residents\n420A (1) This section applies if an individual is temporarily non-resident.\n(2) Debts within subsection (3) are to be treated for the purposes of this Chapter as if they had been released or written off in the period of return.\n(3) A debt is within this subsection if—\n(a) it is the debt, or a part of the debt, in respect of a loan or advance made by a company to the individual,\n(b) it is released or written off in the temporary period of non-residence, and\n(c) ignoring this section, the individual—\n(i) is not liable for tax under this Chapter in respect of the release or write-off, but\n(ii) would have been so liable, had the release or write-off taken place in the period of return.\n(4) Subsection (3)(c)(i) includes a case where the individual could be relieved of liability on the making of a claim under section 6 of TIOPA 2010 (double taxation relief), even if no claim is in fact made.”",
  "extent": null,
  "status": null,
  "version": "current",
  "annotations": [],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/ukpga/2013/29/schedule/45/paragraph/136",
    "retrieved_at": "2026-10-29T09:08:06.076240+00:00"
  },
  "licence": "Open Government Licence v3.0",
  "licence_url": "https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/",
  "attribution": "Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives."
}