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Inland Revenue

Tax Policy

Announcements
PUBLISHED 4 December 2025

Consultation on taxation of company loans to shareholders

Inland Revenue has launched public consultation on proposals to improve the way new loans by companies to shareholders are taxed.

The main proposal is for a new time limit rule that would treat certain shareholder loans as dividends if not repaid within 12 months from the end of the income year they were made. This proposal would only apply to new loans, not existing ones, and only when a company’s total lending to shareholders is $50,000 or more.

Consultation closes on 5 February 2026.

For more information see: