I can't find clear guidance on this anywhere, and a similar question from over a year ago on Accounting Web had zero responses.
An Irish company lends money to a UK company and writes off the loan as non-recoverable. They are both under common control. If both UK companies the result is tax neutral as they are connected parties and treatment is clear, ie debtor company isn't taxable on the gain on write off and creditor can't claim bad debt relief (deed of waiver needed?)
What about in this case with an Irish company writing off a loan to an English company under common control, any expert advice out there please?
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This is an Irish tax question. There may be some AWeb users who feel qualified to advise, but surely this is a question for the Irish company's Irish tax advisers.