@CanadianJohn
My understanding…
She has a limited company, and at the heyday in 2016, this company made £200k (global bonus, commissions from FL)
The accountants put through an equal an opposite ‘provision’ of £200k so her limited company would avoid having to pay corporation tax.
Instead of taking the cash out as income or dividends (and paying tax on it), a directors loan was taken out.
overdrawn DLAs are taxed as of income… however there is illegal ‘bed and breakfasting’ going on where the accountant notes the loan is repaid and taken out as a new loan each year.
She doesn’t actually owe ‘£200k’ as the provision of £200k is likely a provision to pay her a salary.
So to sort it out, she can take it as a dividend and company would owe corporation tax as would release the provision.
Or she can take it as income, pay income tax, and company will have to pay NI.
Both ways, you’re looking at around £100k owing to HMRC via corporation tax/NI/income/dividend tax which has never been paid.
Basically - it’s a tax dodge - you can’t make £200k and pay no tax. Not many accountants would agree to this treatment.