RE: Rns23 Jun 2022 12:48
Newuncle, Groups are required to assess the recoverability of inter-company debts and, as such, can choose to write down or waive (forgive) debts if appropriate. Both adjustments effectively disappear on consolidation in the group accounts but, at the entity company level, a write down is a "one-sided" provision (the liability to pay all or part of the debt is provided in the payee but not in the payer) which may be reversed at a later date if the debt is subsequently reassessed as recoverable, whereas a waiver is accounted in both companies and is "permanent". Neither inter-company provisions nor debt waivers have any UK tax bearing (the transactions are excluded in computing taxable profits/losses).
The fact that the term forgiven was used suggests that the £3.2m was permanently waived. It would appear that the group considers the remaining £1.2m to still be recoverable i.e Innoven UK is expected to be generate sufficient future profits to enable it to repay the inter-company debt.
In a group context, whether or not a debt is waived is largely irrelevant; it generally has no bearing on the group's borrowing capabilities and if the company subsequently recovers and becomes profitable, it can always pay inter-company dividends which are neither taxable or deductible for UK tax purposes. However, a debt waiver can improve the balance sheet of the payer and can be advantageous in the event of a future sale or listing. I wouldn't read too much into it at this juncture (from the group's perspective, waiving all, or part, of the debt can be administratively easier and more pragmatic - no longer have to continuously re-assess the recoverability of the debt each and every year). The fact that some of the debt wasn't forgiven may simply have been a reflection of the group's short term income expectations (to assess the recoverability of a debt you have to project future cash flows and the further forward you project the less certain those projections become); it may just reflect their next 2-3 year income expectations.