CFM35525 - Loan relationships: connected companies and impairment: debtors: deemed releases of impaired debt: deemed releases on or after 14 October 2009: 바카라 사이트˜release of relevant rights바카라 사이트™: example
Debt buybacks: example
DS Ltd was a struggling company that owed £100,000 to its parent company LM Ltd. KJ Ltd was an unconnected company formed by two former managers of DS Ltd, who thought they could turn round DS Ltd바카라 사이트™s business. KJ Ltd came to an arrangement with LM Ltd to buy from it
- the shares in DS Ltd and
- its loans to DS Ltd.
DS Ltd was then completely independent of its former parent. KJ Ltd paid £40,000 for the loans, their market value. KJ Ltd did not bring in any credits in respect of the acquired debt.
On the assumption that KJ Ltd바카라 사이트™s acquisition of the shares and debt of DS Ltd took place before 18 November 2015, and met the conditions for the corporate rescue exception in CTA09/S361A (CFM35540), there was no 바카라 사이트˜deemed release바카라 사이트™ on DS Ltd of £60,000. However, if KJ Ltd then releases the entire debt from DS Ltd, there will be a 바카라 사이트˜release of relevant rights바카라 사이트™ of £60,000 under CTA09/S358(4) (CFM35520).