Debt write-off is not deductible for CGT


If a person who has borrowed to acquire or enhance an asset is subsequently released from some or all of that debt, a deduction cannot be claimed for the amount of the debt forgiven, where the asset is subsequently disposed of. If the debt is forgiven after the asset has been disposed of then the debt release will be deemed to be a chargeable asset in that year and CGT may arise. According to Revenue, the purpose of the amendment to CGT legislation is to ensure that a CGT loss is not available to a taxpayer where no economic loss arises. The Committee Stage of the Finance Bill may give rise to amendments to some related issues such as the treatment of inter-group debt write-offs and connected party disposals.