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HMRC internal manual

Corporate Finance Manual

HM Revenue & Customs
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Introduction to the Corporate Finance Manual: what is not in the Corporate Finance Manual?

Where else can I look?

The Corporate Finance Manual (CFM) contains guidance on the corporation tax treatment of loan relationships and derivative contracts and closely related subjects. You may need to look in one of more of HMRC’s other manuals for further guidance on a number of subjects which are related to corporate finance.

Other guidance on company taxation

Look in HMRC’s Company Taxation Manual (CTM) for guidance on such matters as

  • the corporation tax treatment of dividends and distributions
  • the deduction of tax from interest
  • the rules on close companies, including directors’ loan accounts.

Sometimes the gain on a financial instrument is taxable under the rules on corporate gains - see the Capital Gains Manual (CG).

Instead of borrowing money to acquire an asset, a business may use a finance lease - see the Business Leasing Manual (BLM) for more details.

Non-corporate businesses and individuals

For the most part, the CFM only covers the rules that apply for corporation tax purposes. For details of the income tax rules that apply to unincorporated businesses see the Business Income Manual (BIM).

For details of the income tax rules that apply to the non-business income of individuals, see the Savings and Investment Income Manual (SAIM).

You should note, however, that some of the rules that apply in highly specialised circumstances are also relevant to non-corporate businesses (for example, the material on stock lending and repos CFM46000).

Property income

Guidance on the taxation of property businesses is to be found in the Property Income Manual (PIM) and in the Guidance on Real Estate Investment Trusts Manual (GREIT).

Insurance businesses

The Life Assurance Manual (LAM) and the General Insurance Manual (GIM) explains the application of the corporation tax rules on loan relationships and derivative contracts in the taxation of insurance businesses.


There are very few special rules on the taxation of corporate finance that apply specifically to the banking sector. Material that was formerly to be found in the Banking Manual has been absorbed into the Corporate Finance Manual and the International Manual, and the Banking Manual has now been withdrawn. See CFM1170.

Indirect tax

The VAT Finance Manual has guidance on VAT and financial services.

International issues

The Corporate Finance Manual explains the tax rules on corporate finance from the perspective of domestic taxation. For guidance on cross-border taxation (for example, intra-group funding, thin capitalisation) see the International Manual.