For the purposes of this guide, an 'at call' loan (or related party 'at call' loan) is a loan to a company, by a connected entity (including a controlling shareholder or director), that does not have a fixed term and is repayable on demand by the connected entity (that is, the lender). These loans are sometimes referred to as related party or credit shareholder loans.
'At call' loans may be classified as giving rise to either debt or equity interests in the company for tax purposes under the debt/equity rules. However, some companies that satisfy a turnover carve-out are excluded from the application of the debt/equity rules. An explanation of this carve-out is provided below.