INTM217100 | Controlled Foreign Companies: The CFC charge gateway chapter 9 - exemptions for profits from qualifying loan relationships: what is a qualifying loan relationship: the ultimate debtor rule - detailed application: contents

The “ultimate debtor” condition ensures that a qualifying loan relationship is defined by reference to who, in substance, the real borrower is. TIOPA10/Part 9A/S371IG(2) provides that the ultimate debtor is the immediate debtor in relation to a qualifying loan relationship (“QLR” - INTM217000) unless section 371IG(3) applies to look through any conduit type arrangements