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Official guidance
International Manual

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

  • INTM203310 · UK Activities
  • INTM203320 · Significant People Functions (SPFs)
  • INTM203330 · Identification of Significant People Functions (SPFs)
  • INTM203340 · Example of a structural intra-group loan created with UK Significant People Functions (SPFs) on the occasion of a third party acquisition
  • INTM203350 · Example of a standard cash pooling arrangement located offshore
  • INTM203360 · Example of a third party acquisition with an existing overseas financing company
  • INTM203370 · Example of UK Significant People Functions (SPFs) and “non-vanilla” loans
  • INTM203380 · Location of the Significant People Functions (SPFs)
  • INTM203390 · Attribution to a UK permanent establishment
  • INTM203400 · Calculation of Chapter 5 profits
  • INTM203410 · Risk assessment on Significant People Functions (SPFs)
  1. Controlled Foreign Companies: The CFC Charge Gateway Chapter 5 - Non-trading finance profits: UK Activities: contents
  2. Controlled Foreign Companies: The CFC Charge Gateway Chapter 5 - Non-trading finance profits: UK Activities: Calculation of Chapter 5 profits

INTM203400 | Controlled Foreign Companies: The CFC Charge Gateway Chapter 5 - Non-trading finance profits: UK Activities: Calculation of Chapter 5 profits

From HM Revenue & Customs · International Manual

TIOPA10/S371DB(1) Step 7

The CFC’s non-trading finance profits are re-determined in accordance with step 7 by omitting assets and risks attributed to the assumed UK permanent establishment of the CFC. The non-trading finance profits passing through the CFC charge gateway under Chapter 5 are those profits that are as a consequence left out of the CFC’s re-determined profits.

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