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A Goald & Co Reference Guide

Shareholder Loans in Canada:
The One-Year Rule and Its Traps

Borrowing from your own corporation feels simple. The tax rules behind it are not, and the cost of getting them wrong is your full marginal rate.

15(2)Loan included in income
1 yearAfter year-end to repay
80.4Deemed interest benefit
2026Reviewed October
Simple Summary

The short answer.

The Basics

What a shareholder loan actually is.

Your accountant tracks a shareholder loan account for every owner. Personal expenses paid by the company, cash withdrawals without payroll or dividends, and money you lend to the company all flow through it. A debit balance means you owe the company. A credit balance means the company owes you.

A debit balance is not automatically a problem. It becomes one when it stays outstanding past the deadline in subsection 15(2).

The Rule

The one-year repayment rule.

Subsection 15(2) includes a loan to a shareholder in that person's income. Subsection 15(2.6) excludes it if the loan is repaid within one year after the end of the corporation's tax year in which it was made, and the repayment is not part of a series of loans or other transactions and repayments.

Example: a corporation with a December 31 year-end lends its owner $80,000 in March 2026. The owner has until December 31, 2027 to repay. If it is not repaid, the full $80,000 is added to the owner's 2026 income, taxed at their marginal rate, and the corporation gets no deduction.

Repaying on December 30 and borrowing it back on January 2 is exactly the series pattern CRA looks for. Repayments are generally applied to the oldest loans first.

Interest

The deemed interest benefit.

Under section 80.4, if a shareholder loan carries interest below CRA's prescribed rate, the difference is a taxable benefit, unless the loan is already included in income under 15(2). The prescribed rate is set quarterly. Interest actually paid by January 30 of the following year reduces the benefit.

Exceptions

When loans are allowed.

Subsection 15(2.4) has limited exceptions for loans received because of employment rather than shareholding: for example, to buy a home, a car used for work, or newly issued shares of the company, with bona fide repayment terms. CRA looks closely at whether a non-owner employee would have received the same loan. For most owner-managers of small corporations, relying on this exception is risky.

Better Options

Taking money out instead.

Most shareholder loan problems are a symptom: the company has surplus cash and the owner needs money personally. The usual answers are salary, dividends, a credit-balance withdrawal, a capital dividend if the CDA has a balance, or planning that moves value to the next generation more efficiently.

For owners whose company holds more than it needs, a common question is whether that surplus should sit in taxable investments or be used for corporate-owned permanent insurance, which can grow tax-sheltered and later pay out through the capital dividend account. See how to take money out of a corporation.

Questions

Frequently asked questions.

How long do I have to repay a shareholder loan in Canada?

Generally until one year after the end of the corporation's tax year in which the loan was made. If it is not repaid by then, or the repayment is part of a series of loans and repayments, the loan is included in the shareholder's income for the year it was made.

Do I have to charge myself interest on a shareholder loan?

If the loan bears no interest or interest below CRA's prescribed rate, the difference can be a taxable benefit under section 80.4, unless the loan is already included in income under subsection 15(2).

What happens if the company owes me money?

If your shareholder loan account has a credit balance, the company owes you that amount. You can generally withdraw it tax-free because it represents money you already put in or income already taxed.

Can I borrow from my corporation to buy a house?

Subsection 15(2.4) allows certain loans to employees to buy a home, but the loan must be received because of employment, not shareholding, with bona fide repayment terms. For most owner-managers this exception is difficult to rely on.

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Sources & References

Primary sources cited in this guide

  1. Income Tax Act s. 15 — Benefits conferred on shareholders, including 15(2), 15(2.4), 15(2.6)
  2. Income Tax Act s. 80.4 — Loans: deemed interest benefit
  3. CRA Income Tax Folio S1-F3-C3 — Shareholder loans and debts

Disclaimer. This guide is general educational information published by Goald & Co Financial Inc. It is not tax, legal or accounting advice. Examples are illustrative composites, not real clients. Outcomes vary by province, corporation and shareholder facts and changes in law. Verify every figure with your CPA and legal counsel before acting.