INTM218750 | Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: Full Exemption - Qualifying Resources: What are Qualifying Resources?: contents
From HM Revenue & Customs · International Manual
Qualifying resources are defined by reference to the borrower’s territory: this is called the ‘relevant territory’ and must be identified before it is possible to determine whether resources are qualifying resources. In outline, the categories of qualifying resource are:
profits from lending to the territory;
profits earned in the territory;
Qualifying Resources arising from shares issued by the group top company;
share for share exchanges;
funds derived from share issues.
Contents4 entries
- INTM218760Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: Full Exemption - Qualifying Resources: What are Qualifying Resources?: Categories of Qualifying Resource
- INTM218770Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: Full Exemption - Qualifying Resources: What are Qualifying Resources?: Profits from lending to the territory: contents
- INTM218800Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: Full Exemption - Qualifying Resources: What are Qualifying Resources?: Funds derived from shares: contents
- INTM218850Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: Full Exemption - Qualifying Resources: What are Qualifying Resources?: Evidence Required: contents