How is a DLA released on insolvency treated?

Is a DLA released on insolvency treated as a distribution? At what point

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Client company gone into liquidation with debit Director's Loan Account balance.

Client unable to repay DLA and has therefore entered IVA to repay part of the DLA over three years.

The final balance will not be known until the IVA finishes as potentially more can be paid off if client's financial position improves later.

Is the amount released by the IP at the end of the IVA treated as a distribution and hence subject to tax and NIC as notional dividend income?  Presumably the date of the distribution will be when the IVA ceases and the final balance released?

thanks.

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