Connected company loan write off

Connected company loan write off

Postby The Prisoner on Mon Jan 16, 2012 10:45 am

A French parent loans a UK sub £3m to purchase wine (dr purchases, cr interco loan a/c).

The French parent then releases the loan. My initial thought would be that since they are connected cos there is no taxable credit in the UK sub's books.

But is this still the case given that the UK sub has obtained a £3m deduction for purchases of wine? The sub gets relief for the wine but is not taxed on the release. Is that right?
The Prisoner
 
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