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Small business owner transferring personal funds into the company: Shareholder loan or capital contribution? Full tax guide

May 24, 2026 · Company Registration · Glow Pacifier Consulting

How exactly should I transfer money from personal to business accounts?

Many Chinese small business owners face this scenario: the company account is empty, and you transfer money from personal savings to cover it. Or you just registered a company and deposited your own savings as startup capital. The money goes in, but how do you book it? Can you take it back later? Will the tax authorities come after you?

In Canadian tax law, transferring funds from an individual to a corporation has two paths:Shareholder Loan(shareholder loan) andCapital Injection(capital contribution/equity). Which path you choose directly affects whether you'll pay tax when withdrawing money later.

💡 Core difference in one sentence

Shareholder Loan = Money the Company Owes You, Can Be Withdrawn Anytime, Tax-Free.
Capital injection = permanently locked in equity, requiring complex tax procedures to withdraw.

For most small businesses,Shareholder Loans Are More Flexible

Shareholder loans: how to do it safely?

When you transfer money into the company and record it as 'company owes shareholder' (accounting entry called 'Due to Shareholder'), you become the company's creditor. This amount is on the books asLender Balance(credit balance) is a liability for the company and a receivable for you.

The Good News:CRA basically doesn't audit lender balances (you lending money to the company).Section 15(2) of the Income Tax Act only applies when a company lends money to a shareholder (debit balance), not the reverse. If you withdraw this money, it counts as a repayment, not income, and is not taxable. There is no time limit—you can withdraw it whenever you want.

But that doesn't mean you can do nothing. It's recommended to keep:

These documents don't need to be filed with the CRA, but if you're audited, paper evidence is a hundred times better than saying 'I lent it to the company.'

When should you use capital contributions?

Capital injection means turning your money into equity—issuing new shares and increasing paid-up capital. This route is suitable for:

The catch: once you inject capital, getting it back isn't as simple as writing a cheque. You'll need to go through a capital reduction, share buyback, or company liquidation—all of which involve corporate law procedures. Any amount exceeding the PUC is treated by the CRA as a deemed dividend and is taxable.

The flip side: a company lending money to shareholders—that's what the CRA really watches

The above covers moving money into your company. Conversely, when you take money out of the company for personal use, creating a Due from Shareholder balance on the books, that's where you can really get into trouble.

CRA Income Tax ActSection 15(2)Core rule: if a company lends money to shareholders, it mustRepay within one year after the company's fiscal year-endDon't repay? The entire loan amount is counted as your personal income, and you'll owe tax that year.

⚠️ Key Timeline

Your company's fiscal year ends December 31. You borrowed $50,000 from the company on March 15:
Repayment Deadline = December 31, 2027(One year after fiscal 2026 ends)
If not repaid → $50,000 fully included in 2026 personal income

Don't forget: the top personal marginal tax rate is 53.53% (Ontario), and the corporation has already paid tax on this profit. Paying personal income tax again meansDouble Taxation

One more easy to forget: interest

Even if you repay the loan on time, as long as the company didn't charge you interest, CRA will have another bill:Deemed Interest Income(deemed interest benefit, Section 80.4).

Calculated based on the CRA's quarterly published ratePrescribed Interest Rate × Your average amount owed to the company ÷ 12 × number of months owed. The prescribed rate for Q2 2026 is3%

Example: If you owe your company $100,000 on average over the year at zero interest, CRA will add $3,000 in interest income to your personal return, and you must pay tax on that.

How to avoid: annuallyWithin 30 days after the company's fiscal year-endPay interest to the company. The interest rate must be at least the CRA prescribed rate. Note: Interest paid after 30 days cannot be used to offset the deemed interest income for that year. (Conversely, interest received by the company counts as company income.)

10 common mistakes Chinese business owners make

#errorConsequences
1Default: all incoming transfers are treated as 'capital contributions'Money locked up in equity, inaccessible
2No borrowing documentsUnable to prove it's a loan during a CRA audit
3Missed a one-year repayment deadlineFully included in personal income, double taxation
4"Repay at year-end, borrow again at year-start" cycleDeemed a 'series of transactions' by the CRA, the 15(2.6) exception does not apply.
5Unaware That Interest Is ChargedReport deemed interest income annually
6Paying personal expenses with company funds without recording themDebit balance quietly accumulates, year-end blowup
7Thought year-end accrued bonuses could offset the loanCRA does not automatically recognize it; you must issue formal payroll and remit deductions
8Organize accounts only when filing taxesThe repayment clock starts at the end of the fiscal year, not the tax filing deadline
9Forgot that spouse/children's loans also countSection 15(2) also applies to related persons
10Even if the company owes you money, write an IOUDue to Shareholder balances don't require a promissory note, but it's recommended to record the amount and transfer date.

What if I've already missed a payment deadline?

Two Remediation Paths:

  1. Payroll/Bonuses:Process it through formal payroll, record T4 wages to offset the debit balance. The individual must pay payroll taxes, but this avoids double taxation under 15(2).
  2. Issue Dividends:Use T5 dividends to offset the debit balance. Dividend tax rates are lower than salary, but the company side cannot deduct them.

Both paths are better than getting caught under 15(2). Under 15(2), the company can't deduct, and the individual must pay back taxes—worst case.

Summary: Remember three principles

  1. Money goes into the company → record it as a shareholder loan (Due to Shareholder), flexible, withdraw anytime tax-free.
  2. Taking money out of the company → Keep an eye on the one-year deadline after fiscal year-end, repay on time or use salary/dividends.
  3. Keep your documents.A one-page borrowing resolution is more effective than ten thousand words of explanation.

Frequently Asked Questions

Do shareholder loans need to charge interest?

You lend money to the company (credit balance): legally, you don't need to charge interest, but if you do, it's investment income and must be reported. No tax penalty for not charging interest. Conversely, the company lends money to you (debit balance): interest must be charged, or CRA deems it a taxable benefit.

How to distinguish between loans and capital injections?

Look at three things: Is there an intention to repay (loans have it, capital contributions don't)? Is interest being paid (loans usually do, capital contributions don't)? The accounting entry (loans are recorded as a liability 'Due to Shareholder,' capital contributions as equity 'Share Capital'). It's best to have a board resolution clearly stating whether it's a loan or a capital contribution.

Do I need an accountant?

If you only occasionally transfer a few thousand dollars for cash flow, self-bookkeeping is fine. But if the debit balance is tens of thousands and unpaid for years, or involves transfers among multiple shareholders, it's best to find a CPA who knows small business tax to help with tax planning. The tax savings will outweigh the consulting fees.

Frequently Asked Questions

Q: Does a shareholder need to charge interest when lending money to the company?

When a shareholder lends money to the company (credit balance), there is no legal requirement to charge interest. If you do charge interest, it's investment income and must be reported. Not charging interest has no tax penalty.

Q: How long does a company have to repay a loan to a shareholder?

When a company lends money to a shareholder (debit balance), it must be repaid within one year after the company’s fiscal year-end. If not, the CRA will include the full amount as personal income.

Q: How do I distinguish between shareholder loans and capital contributions?

Look at three things: whether there's intent to repay, whether interest is paid, and whether the accounting entry is a liability or equity. Recommend a board resolution clearly stating the nature.

Q: If I miss the repayment deadline, can I still make it right?

Yes. Offset the loan balance by issuing formal payroll (T4) or dividends (T5). Both routes are better than being taxed under Section 15(2).

Q: Does money taken by a spouse from the company also count?

Yes. Section 15(2) applies to all related persons, including spouses and minor children, as long as the loan is obtained through shareholding.

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