476. Loans released or written off.

Where:

  1.  

    (1)     a company is or was chargeable to tax1 in respect of a loan or advance made to the trustees of a settlement2;

  2.  

    (2)     the company releases3 or writes off the whole or part of the debt in respect of the loan or advance;

  3.  

    (3)     the person from which the debt was due at the time of the release or writing off is a company; and