The Irish Tax Appeals Commission has published Determination 52TACD2022 - Corporation Tax, concerning the treatment of a loan waiver as taxable profits or gains for a group treasury company. The case involved an amended notice of assessment to corporation tax in the sum of EUR 25,614,160.50, raised on the Appellant company on 29 November 2018 in respect of the year ended 31 December 2013. The notice of assessment raises a charge to corporation tax in respect of a loan waiver in the sum of US…