I have tracked down a pdf print of an earlier Corporation Tax effective from 01.0.2007
and scroll down to Tax Law. This is what the original Article 46 states:
Tax Treatment of Debts
Article 46. (1) Upon determination of the tax financial result, the accounting financial result shall be credited with the
amount of the debts of the taxable person originating from amounts which lead to a diminution in the tax financial result, and
the said crediting shall be effected in the year in which one of the following circumstances occurs:
1. the debts are extinguished by prescription, but not more than five years after the time when the debt became
2. the bankruptcy proceedings against the taxable person have been closed by a confirmed plan for rehabilitation
which provides for incomplete satisfaction of the creditors; the crediting shall be effected by the amount of the diminution in
3. an effective judgement of court has decreed that the debt or part thereof is undue;
4. the creditor has relinquished the claim thereof by a judicial procedure or has redeemed the said claim; the crediting
shall be effected by the amount redeemed;
5. before the lapse of the prescription period, the debts have been extinguished by virtue of a law;
6. the taxable person has submitted a motion for expungement.
(2) The accounting income accounted for in connection with a write-off of the debts referred to in Paragraph (1) shall
not be recognized for tax purposes.
The original section was definately aimed at reversing expenses/payments from trade creditors that in an earlier period reduced taxable profits and continued to remain unpaid:
the accounting financial result shall be credited with the amount of the debts of the taxable person originating from amounts which lead to a diminution in the tax financial result,
Me loaning my company funds to buy property hasn't lead to a diminuation in my company's tax financial results. The only time this may be seen to happen is when having sold the property I come to repay myself out to the profits of the sale, I draw down my director loan instead of taking the funds out as a dividend.