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A company sought clarification on when it could deduct as an expense the final loss from a loan granted to a related party that entered insolvency proceedings. The DGT ruled that, because the entities are related, deductibility requires the debtor to be in insolvency proceedings and for the liquidation phase to have officially commenced.
This ruling clarifies the strict requirements for tax deductibility of bad debts involving related parties, specifically linking the deduction to the formal commencement of the liquidation stage in insolvency proceedings.
The tax team reviews your specific situation.
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