Penalties for failure to notify chargeability to tax applied to the late notification of an overdrawn director’s loan account in respect of which tax arose, notwithstanding that the outstanding loans were subsequently repaid.  
 
Summary 
 
Penalties for failure to notify chargeability to tax applied to the late notification of an overdrawn director’s loan account in respect of which tax arose (under CTA 2010, s 455), notwithstanding that the outstanding loans were subsequently repaid.  
 
Background 
 
The appellant company was incorporated on 3 December 2010 and had a sole director. The appellant was late in filing tax returns for the periods ended 2 December 2011, 31 December 2011, 31 December 2012, 31 March 2013, and 31 March 2014. 
 
Shortly after the appellant had filed all outstanding