Company A has traded for some years, 100% owned by director X
Company B is formed, 100% owned by director X
Company A does consultancy work for B to get it set to trade, bills B and pays CT accordingly. Company B does not pay because it has no revenue stream.
In the meantime director X gives 50% of shares to new director Z to market the services. Still company B does not trade and it is decided in time that company B will not trade.
Company A wishes to write off the debt and claim relief. My concern is that as connected companies there is no relief if treatment is under loan relationship rules per CTA09/PT6. Do you agree or what is it I am missing?