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Moving money between companies —
tax implications

August 2026 7 min read By 1494 Group

If you own more than one limited company — perhaps a trading company and a separate property investment company, or a growing business alongside a new venture — moving surplus cash from one to the other is not as simple as an internal bank transfer. Each company is a separate legal entity, and HMRC treats money moving between them as a transaction that needs a proper tax and accounting treatment, even where no interest is charged and the companies are under common ownership.

This post covers the most common way this is done — the intercompany loan — how it is taxed, the rules you need to follow, and the traps that catch directors out.

Why you can't just "move" money between companies

Because each limited company is a distinct legal person, cash cannot simply pass between them without a transaction being recorded. There are broadly three routes: a dividend from one company up to a shared shareholder and back down into the other (inefficient and rarely used for this purpose), a management charge for genuine services provided between the companies, or — by far the most common — an intercompany loan.

An intercompany loan is exactly what it sounds like: one company lends money to another, with the loan recorded as a liability in the borrowing company's accounts and an asset in the lending company's accounts. It is a normal and widely used method of moving cash within a group of connected companies for legitimate business purposes — funding a new venture, financing a property purchase, or providing working capital.

The loan relationship rules

HMRC governs company-to-company lending through the loan relationship rules, part of the Corporation Tax framework. Under these rules:

Because interest is the only element that creates a tax event, and because moving it from one connected company to another simply shifts a Corporation Tax liability from the borrower to the lender without any real overall benefit, many intercompany loans between connected UK companies are made interest-free. An interest-free loan can still qualify as a valid loan relationship under HMRC's rules — there is no requirement to charge interest between connected companies for the arrangement to be recognised, unlike loans to unconnected third parties, which may need to reflect a commercial, arm's length rate.

All loans must be at arm's length. Even between connected companies, the terms should reflect what a reasonable commercial arrangement would look like — properly documented, with clear terms on repayment, even if no interest is charged. This matters both for good governance and in case HMRC ever scrutinises the arrangement.

The associated companies effect on Corporation Tax

If you own more than one company, they will very likely be treated as associated companies for Corporation Tax purposes — broadly, where the same person or persons control both. This has a direct impact independent of any lending between them: the £50,000 and £250,000 Corporation Tax thresholds are divided by the number of associated companies.

So if you own two companies, each one's small profits rate threshold drops from £50,000 to £25,000, and the main rate threshold drops from £250,000 to £125,000. This applies regardless of whether the companies lend to each other — simply owning more than one company changes the tax position of both. Some dormant companies and passive holding companies whose only activity is holding shares and receiving dividends may be excluded from the count, but this needs to be assessed carefully rather than assumed.

Why directors set up intercompany loans

A practical note on financing a property purchase: if the investment is funded partly through an intercompany loan and partly through an external mortgage, it is generally advisable for the investing (non-trading) company to hold the property, rather than the trading company. Lenders typically require personal guarantees or a debenture — a fixed and floating charge — over the borrowing entity. Most directors prefer this charge to sit over a non-trading investment vehicle rather than over the company that carries their day-to-day trading risk and livelihood.

What happens if the loan is written off

Sometimes an intercompany loan is never repaid — perhaps the borrowing company's venture did not work out, or the group decides to formally release the debt. Writing off an intercompany loan has tax consequences that depend on the specific circumstances and the relationship between the companies:

Given how easily these situations can be misclassified, and the meaningful tax difference between a "connected" write-off and an unconnected one, this is an area where getting professional advice before writing off a balance — rather than after — makes a real difference.

Transfer pricing — a developing area

Transfer pricing rules require that transactions between connected companies — including loans — reflect arm's length terms, so that taxable profits are not artificially shifted between entities. Historically, UK-to-UK transfer pricing between connected companies has had limited practical impact for most small groups, since both entities pay UK Corporation Tax and there is little incentive to manipulate pricing between them.

This is an area of active legislative change. Reforms proposed in the Finance Bill 2026, intended to take effect for accounting periods commencing on or after 1 January 2026, would generally disapply UK-to-UK transfer pricing rules for most connected domestic transactions, subject to limited exceptions designed to prevent tax arbitrage. If you hold companies with any cross-border element — an overseas parent, subsidiary, or connected party — transfer pricing considerations remain far more significant and this area should be reviewed with a specialist.

Getting the basics right

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This article is for general information purposes and does not constitute tax advice. Intercompany lending, loan relationship rules, and transfer pricing are complex areas of law that depend heavily on individual circumstances. Always speak to a qualified accountant before entering into or writing off an intercompany loan.