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Official guidance
International Manual

INTM248100 · Controlled Foreign Companies: Definitions for terms in Part 9A: Alphabetic index of terms defined in Part 9A

  • INTM248150 · Accounting Periods
  • INTM248200 · Accounting profits
  • INTM248300 · Cell companies
  • INTM248350 · Connected persons
  • INTM248400 · Non-trading finance profits
  • INTM248450 · Trading finance profits
  • INTM248500 · Interests in companies
  • INTM248550 · Property business profits
  • INTM248600 · Relevant finance lease
  1. Controlled Foreign Companies: Definitions for terms in Part 9A: Alphabetic index of terms defined in Part 9A
  2. Controlled Foreign Companies: Definitions for terms in Part 9A: Alphabetic index of terms defined in Part 9A: Trading finance profits

INTM248450 | Controlled Foreign Companies: Definitions for terms in Part 9A: Alphabetic index of terms defined in Part 9A: Trading finance profits

From HM Revenue & Customs · International Manual

TIOPA10/S371VG(4) defines trading finance profits as any amounts included in a CFC’s assumed total profits for the accounting period which are treated as trading profits under Part 3 of CTA 2009, but that (if they were not trade profits) would be charged to tax as non-trading finance profits, as defined at INTM248400. They also include trading profits arising from a “relevant finance lease” (see INTM248600).

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