(1). Fay can deduct the interest on the loan to acquire the shares in GFL from her net income because GFL is a close company and Fay owns more than 5% of the company.
(2). GFL is a close company because it is controlled by five or fewer shareholders.
(3). GFL has made a loan to one of its passive investors. However, it would not have been required to make a payment to HMRC if all of the following conditions had been satisfied: