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HMRC internal manual

Capital Gains Manual

From
HM Revenue & Customs
Updated
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Losses: loans to traders: irrecoverability: claims re later loans

As mentioned in CG65954 a lender may have lent money to the borrower on a number of occasions over a period of time. It may happen that loans will have been made to the borrower after the date on which it has been claimed that the earlier loans had become irrecoverable. In such cases you should normally resist claims to relief under Section 253 in respect of the later loans. Unless there was a marked improvement in the borrower’s prospects after the date on which the earlier loans were claimed to have become irrecoverable, any loans made to the borrower after that time will not have BECOME irrecoverable, as they were irrecoverable as soon as they were made. The conditions for TCGA92/S253 will not be met, and relief will not therefore be due.