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Subsidiary loan write off

If a company had a 100% subsidiary which has now ceased trading due to losses, owing the holding company £140k, is there any relief available to the Holding company for the write off of the loan? The loan built up over the period of a year and was largely to fund set up and day to day operating costs.

Any assistance with this would be appreciated.

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By BKD
13th Oct 2011 10:47

Unlikely

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By afairpo
13th Oct 2011 11:22

Generally no relief for release of connected party debts

s354 CTA 2009 - general rule is that no relief for release of debt owed by connected party (which will include a 100% subsidiary).  However, equally, the sub doesn't have to bring the release into account for tax purposes (s358 CTA 2009).

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