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

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.