In multinational corporate groups, it is not uncommon for a shareholder to waive a receivable owed by the company in order to cover losses. In most cases, this transaction is fiscally neutral, as the nominal value of the receivable coincides with its tax value.
However, situations may arise where the ownership of the receivable stems from a more complex financial restructuring within the group, and the nominal value does not match the acquisition cost, which is generally lower. In such cases, it is necessary to determine the tax treatment of the difference between the tax value (typically the acquisition cost) and the nominal value of the receivable.