I'll explain the position:
1. company A loans money to company B (both owned by the same person). This was around 3 years ago and the funds largely refinanced property borrowing in company B (previously from director).
2. loan between 2 companies now written off as no real I ntentions to repay in future.
Typically this would create a CT charge in company B as it's liability to the debt has been released. However the companies are connected so (hopefully) the 'no tax' treatment should apply.
Any thoughts on if this could be challenged by HMRC. The original intention was not a future write off but it now seems a sensible option.