Connected company loan w/off

Connected company loan w/off

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Just want to check that I'm not missing something. Two companies under common control, one incorporated in UK the other incorporated (and managed/controlled) overseas. Loan due to UK Co is to be written off. No deduction for UK Co, no difficulty with that. However, overseas tax rules mean that the credit will be taxable, My understanding is that this asymmetry is just tough - but just want to check that there is no relieving provision in the UK tax code anywhere that covers such circumstances (that would allow a deduction for UK Co).

Assuming that there is no such relief, the suggestion may be to convert loan to share capital in the overseas Co.

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