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HMRC internal manual

Banking Manual

Banking surcharge: targeted anti-avoidance rule: meaning of relevant transfer – CFC chargeable profits

TIOPA10/S371BI(4)

There is a relevant transfer if there is, in substance:

  • a transfer (directly or indirectly) of all or a significant part of the chargeable profits of the CFC to a non-banking company, or
  • a transfer (directly or indirectly) of a loss or deductible amount to the CFC from a non-banking company, resulting in the elimination or significant reduction in the surcharge profits.