CG65958 - Losses: loans to traders: irrecoverability: terms of loan/acts of lender
In accordance with TCGA92/S253 (12), you should not regard any amount as having become irrecoverable where it has so become in consequence of
- the terms of the loan itself,
or
- arrangements of which the loan forms part,
or
- any act or omission by the lender.
These conditions are intended as anti-avoidance protection, to exclude from the relief a variety of devices ranging from the simple gift dressed up as a loan to more sophisticated schemes such as the siphoning of resources out of a company which then becomes unable to repay its loan.