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Official guidance
International Manual

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?

  • INTM218760 · Categories of Qualifying Resource
  • INTM218770 · Profits from lending to the territory
  • INTM218800 · Funds derived from shares
  • INTM218850 · Evidence Required
  1. Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: Full Exemption - Qualifying Resources: contents
  2. 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

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

  1. 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
  2. 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
  3. 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
  4. 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
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