is the write back of DLA credit balance to P&L taxable?
i think the answer is maybe - in this instance it is part of a sale of the shares owned 100% by the director. without the write back the potential buyer of the shares won't proceed so the company would probably apply to be struck off.
i think there is relief under s322 & s323 cta2009 but i am uncertain as to whether this extends to a dla as opposed to inter co debt
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Why does the seller not sell the loan instead or as well as the shares? (Presuming both are his)
Subject to the numbers the purchaser gets a loan to in future possibly withdraw tax free (subject to price paid for the loan of course)
Doesn't that equate to paying less for the shares? Or are you suggesting debt factoring - which is not tax free.
Yes the capitalisation requires a (very simple) accounting entry, and also filing a (very simple) form at Companies House. The debt assignment however requires a legal instrument, no doubt drafted by a lawyer for a nice fee, and is therefore the more complex of the two - although worth it for the purchaser if he realises the advantage it brings him.