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INTM203300 | Controlled Foreign Companies: The CFC Charge Gateway Chapter 5 - Non-trading finance profits: UK Activities: contents

From HM Revenue & Customs · International Manual

Contents11 entries

  1. INTM203310Controlled Foreign Companies: The CFC Charge Gateway Chapter 5 - Non-trading finance profits: UK Activities: UK Activities
  2. INTM203320Controlled Foreign Companies: The CFC Charge Gateway Chapter 5 - Non-trading finance profits: UK Activities: Significant People Functions (SPFs)
  3. INTM203330Controlled Foreign Companies: The CFC Charge Gateway Chapter 5 - Non-trading finance profits: UK Activities: Identification of Significant People Functions (SPFs)
  4. INTM203340Controlled Foreign Companies: The CFC Charge Gateway Chapter 5 - Non-trading finance profits: UK Activities: Example of a structural intra-group loan created with UK Significant People Functions (SPFs) on the occasion of a third party acquisition
  5. INTM203350Controlled Foreign Companies: The CFC Charge Gateway Chapter 5 - Non-trading finance profits: UK Activities: Example of a standard cash pooling arrangement located offshore
  6. INTM203360Controlled Foreign Companies: The CFC Charge Gateway Chapter 5 - Non-trading finance profits: UK Activities: Example of a third party acquisition with an existing overseas financing company
  7. INTM203370Controlled Foreign Companies: The CFC Charge Gateway Chapter 5 - Non-trading finance profits: UK Activities: Example of UK Significant People Functions (SPFs) and “non-vanilla” loans
  8. INTM203380Controlled Foreign Companies: The CFC Charge Gateway Chapter 5 - Non-trading finance profits: UK Activities: Location of the Significant People Functions (SPFs)
  9. INTM203390Controlled Foreign Companies: The CFC Charge Gateway Chapter 5 - Non-trading finance profits: UK Activities: Attribution to a UK permanent establishment
  10. INTM203400Controlled Foreign Companies: The CFC Charge Gateway Chapter 5 - Non-trading finance profits: UK Activities: Calculation of Chapter 5 profits
  11. INTM203410Controlled Foreign Companies: The CFC Charge Gateway Chapter 5 - Non-trading finance profits: UK Activities: Risk assessment on Significant People Functions (SPFs)