CFM5122c - Taxing loan relationships: accounting methods: releases

Giving relief - release of debt

This guidance applies to periods of account beginning before 1 January 2005

Releases of debt are comparatively rare.

A debt is released only when the lender has waived the borrower's obligation to repay. The writing off of a debt in a company's accounts is not a release, because in that situation the borrower's obligation to repay remains.

A release can be of the entire amount of the debt, or part of the debt. When the lender releases a debt, it ceases to be a party to the loan relationship. Its rights have been extinguished, so this is a related transaction (see CFM5067). However,

S85 still applies - the lender must assume that the amount is paid in full , but

Para5(1)(c) requires a departure from this assumption

so a debit for amounts released, in full or in part, is in accordance with the authorised accruals basis.