Corporation Tax Act 2010 section 94

Cases in which government investment is written off

Section 94 sets out the three circumstances in which government investment in a company is treated as having been written off, and explains how the written-off amount may be reduced where replacement public funding is provided.

• A government loan to a company from public funds is written off when the company's obligation to repay it is extinguished, with the written-off amount being the liability extinguished.
• Publicly funded shares subscribed for by a Minister are written off when those shares are cancelled, with the written-off amount being the original subscription price.
• A reduction (other than by repayment) in a company's commencing capital debt or public dividend capital is treated as a write-off, with the written-off amount being the amount of the reduction.
• The written-off amount is reduced to the extent it is replaced by new public loans, payments from public funds, or shares subscribed for by a Minister.