Commentary

141.2 Debts owed by the target company to one or more of the sellers

COMPANIES vol 11 acquisitions, mergers, demergers
| Commentary

141.2 Debts owed by the target company to one or more of the sellers

| Commentary

141.2 Debts owed by the target company to one or more of the sellers

Taxation issues which may arise in respect of debts due or owed between the target company and any of the sellers may involve the following:

  1. 141.2.1

        any surrender, redemption or release of a debt by a company results in it no longer being a party to a loan relationship; but the extinguishing of the debt will be a related transaction under the loan relationship rules—however, writing off the debt will not be a related transaction;

  2. 141.2.2

        if a close company releases the debt of a participator

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