Valuation of Assets and Liabilities other than TPs

Should the value of withholding tax assets be capped at the face value in the Solvency II balance sheet?

When calculating the market value of withholding tax assets we allow for the time value of money by discounting future receivable recoveries using the risk free rates and best estimate cash-flows. As the risk free rate has fallen negative this can results in withholding taxes having a present value above the face value. In this case, should the withholding tax asset equal the present value of receivables (i.e. no capping) or should it equal the face value (capping). Calculating a present value with no capping would be consistent with the methodology used in the BEL calculation, whereas an appoach with capping would include an element of prudence due to the relatively higher uncertainty in the timing of tax receivables compared to policyholder cash-flows.