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INTM198000 | Controlled Foreign Companies: The CFC Charge Gateway Chapter 3 - Determining which (if any) of Chapters 4 to 8 apply: Does Chapter 6 apply?: contents

From HM Revenue & Customs · International Manual

Does Chapter 6 apply?

Chapter 6 (trading finance profits) applies for a CFC’s accounting period only if the CFC has trading finance profits and at any time during the accounting period it has funds or other assets derived directly or indirectly from UK connected capital contributions (see INTM198050).

See INTM248450 for a full definition of trading finance profits, but broadly they are profits arising from loan relationships, derivative contracts or company distributions that are included in a trade profits computation.

Contents2 entries

  1. INTM198050Controlled Foreign Companies: The CFC Charge Gateway Chapter 3 - Determining which (if any) of Chapters 4 to 8 apply: Does Chapter 6 apply?: Funds or other assets derived directly/indirectly from UK connected capital contributions
  2. INTM198100Controlled Foreign Companies: The CFC Charge Gateway Chapter 3 - Determining which (if any) of Chapters 4 to 8 apply: Does Chapter 6 apply?: Group treasury companies