{
  "url": "https://openlegislation.uk/income-tax-earnings-and-pensions-act-2003/section-446S",
  "json_url": "https://openlegislation.uk/income-tax-earnings-and-pensions-act-2003/section-446S.json",
  "legislation": "ukpga/2003/1",
  "legislation_title": "Income Tax (Earnings and Pensions) Act 2003",
  "legislation_url": "https://openlegislation.uk/income-tax-earnings-and-pensions-act-2003",
  "path": "section/446S",
  "kind": "section",
  "number": "446S",
  "heading": "Notional loan",
  "text": "(1) Where this Chapter applies an interest-free loan (“the notional loan”) is to be treated as having been made to the employee by the employer at the time of the acquisition.\n(2) The provisions listed in subsection (3) apply as though the notional loan were an employment-related loan as defined in section 174 if and for so long as the employment has not terminated.\n(3) The provisions are—\nsection 175 (benefit of taxable cheap loan treated as earnings),\nsection 178 (exception for loans where interest qualifies for tax relief),\nsection 180 (threshold for benefit of loan to be treated as earnings),\nsection 182 (normal method of calculation: averaging),\nsection 183 (alternative method of calculation),\nsection 184 (interest treated as paid),\nsection 185 (apportionment of cash equivalent in case of joint loan etc), and\nsection 187 (aggregation of loans by close company to director).\n(4) This section is not affected by section 554Z2(2).",
  "extent": "E+W+S+N.I.",
  "status": null,
  "version": "current",
  "annotations": [
    {
      "type": "F",
      "label": "F1",
      "text": "Pt. 7 Ch. 3C inserted (with effect in accordance with Sch. 22 para. 7(2) of the amending Act) by Finance Act 2003 (c. 14), Sch. 22 para. 7(1)"
    },
    {
      "type": "F",
      "label": "F2",
      "text": "S. 446S(4) inserted (with effect in accordance with Sch . 2 para. 52-59 of the amending Act) by Finance Act 2011 (c. 11), Sch. 2 para. 21"
    }
  ],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/ukpga/2003/1/section/446S",
    "retrieved_at": "2026-10-29T09:18:42.395488+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."
}