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Contents

Official guidance
International Manual

INTM216600 · Controlled Foreign Companies: The CFC charge gateway chapter 9 - exemptions for profits from qualifying loan relationships: scope of the rules

  • INTM216650 · Business premises condition
  • INTM216700 · General exclusions
  • INTM216750 · Loan relationship for chapter 9 purposes
  • INTM216800 · The chapter 9 claim
  • INTM216850 · Order of the chapter 9 claim
  • INTM216900 · Chapter 9 and double taxation relief
  1. Controlled Foreign Companies: The CFC charge gateway chapter 9 - exemptions for profits from qualifying loan relationships: scope of the rules: contents
  2. Controlled Foreign Companies: The CFC charge gateway chapter 9 - exemptions for profits from qualifying loan relationships: scope of the rules: general exclusions

INTM216700 | Controlled Foreign Companies: The CFC charge gateway chapter 9 - exemptions for profits from qualifying loan relationships: scope of the rules: general exclusions

From HM Revenue & Customs · International Manual

  • TIOPA10/Part 9A/Ch 9/S371IA(9) excludes from a CFC charge under Chapter 9 any non- trading finance profits (“NTFPs”) where they:

  • arise from the investment of funds held by the CFC for trading purposes;

  • arise from the investment of funds held by the CFC for the purposes of a property business;

  • fall within Chapter 8 (solo consolidation - INTM213000);

  • arise from a relevant finance lease - INTM248600.

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