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HMRC internal manual

Corporate Finance Manual

Loan relationships: connected companies: impairment: exceptions from the restrictions on debits for impairment

Summary of exceptions

There are two exceptions to the restriction in CTA09/S354. These are

  • where a debt is written off or released by the creditor in exchange for shares in the debtor - a debt for equity swap (CFM35380);
  • where the creditor is insolvent (CFM35410).