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Contents

Official guidance
Corporate Finance Manual

CFM35300 · Loan relationships: connected companies and impairment

  • CFM35310 · Overview
  • CFM35320 · Basic rules
  • CFM35330 · Basic rules: example
  • CFM35340 · Basic rules: related transactions
  • CFM35350 · Basic rules: related transactions: examples
  • CFM35360 · Cessation of connection
  • CFM35370 · Loan relationships: connected companies: impairment: exceptions from the restrictions on debits for impairment
  • CFM35380 · Exceptions: debt-equity swaps
  • CFM35390 · Debt-equity swaps: examples
  • CFM35400 · Exceptions: debt-equity swaps: CG aspects
  • CFM35410 · Exceptions: insolvent creditors
  • CFM35420 · Debtors
  • CFM35430 · Debtors: deemed releases of impaired debt
  • CFM35435 · Debtors: History to the deemed release rules
  • CFM35440 · Debtors: deemed releases of impaired debt: tax treatment
  • CFM35450 · Debtors: deemed releases of impaired debt: where impaired debt is acquired
  • CFM35460 · Debtors: deemed releases of impaired debt: where impaired debt is acquired: example
  • CFM35470 · Debtors: deemed releases of impaired debt: where impaired debt is acquired: further example
  • CFM35480 · Debtors: deemed releases of impaired debt: where holders of impaired debt become connected
  • CFM35490 · Debtors: deemed releases of impaired debt: where holders of impaired debt become connected: examples
  • CFM35500 · Debtors: deemed releases of impaired debt: where holders of impaired debt become connected: further example
  • CFM35505 · Debtors: deemed releases of impaired debt: where holders of impaired debt become connected: connection on or after 1 April 2012: examples
  • CFM35510 · Debtors: deemed releases of impaired debt: deemed releases on or after 14 October 2009: overview
  • CFM35520 · Debtors: deemed releases of impaired debt: deemed releases: ‘release of relevant rights’
  • CFM35525 · Debtors: deemed releases of impaired debt: deemed releases on or after 14 October 2009: ‘release of relevant rights’: example
  • CFM35530 · Debtors: deemed releases of impaired debt: exemptions
  • CFM35540 · Debtors: deemed releases of impaired debt: deemed releases : the 'old' corporate rescue exemption
  • CFM35550 · Debtors: deemed releases of impaired debt: the 'old' debt-for-debt exemption
  • CFM35560 · Debtors: deemed releases of impaired debt: the equity-for-debt exemption
  • CFM35570 · Debtors: deemed releases of impaired debt: the 'new; corporate rescue exemption from S361
  • CFM35580 · Debtors: deemed releases of impaired debt: the corporate rescue exemption from S362
  • CFM35590 · Debtors: deemed releases of impaired debt: anti-avoidance rule
  • CFM35595 · Debtors: deemed releases of impaired debt: anti-avoidance rule: examples
  1. Loan relationships: connected companies and impairment: Contents
  2. Loan relationships: connected companies: impairment: exceptions from the restrictions on debits for impairment

CFM35370 | Loan relationships: connected companies: impairment: exceptions from the restrictions on debits for impairment

From HM Revenue & Customs · Corporate Finance Manual

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).

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