Corporation tax relief on investment impairment

Corporation tax relief on unlisted investment impairment

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My client is a contractor with a Ltd company. The company was "paid" in shares (unlisted company and not connected) rather than cash for one of his invoices. These shares are now worth a lot less than the original value. He will still need to pay corporation tax on the invoice issued as this is income but can he get tax relief on the impairment of the investment even if he still holds the shares?

I have been reading CFM33220 and it seems to suggest that as long as they are not treated as Fair Value Through The P&L then tax relief should be available and as they are unlisted investments then this should be ok but would be very grateful if someone could confirm?

Thanks in advance

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