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HMRC internal manual

Corporate Finance Manual

Introduction to the Corporate Finance Manual: how to use the Corporate Finance Manual

Internal users and professional advisers

The CFM is mainly intended for HMRC staff and external professional advisers who need to find out the correct technical position on the corporation tax treatment of loan relationships, foreign exchange and derivative contracts. The following is a guide to using the CFM.

Tables of contents

At the beginning of each chapter there is a table of contents, and there are subcontents pages at the beginning of each section within the chapters. Use these to navigateto the pages you need.


Internal users can search the CFM by clicking the ‘Search all manuals’ button at the top right of each manual page.

You then should enter your search query and the manual ref ‘CFM’ on the left hand side of the following page before pressing ‘refine search’ to bring up the results.

Internet users cannot use the left bar. Instead use the ‘search this manual box using your chosen keywords and look for results in the CFM.

Sometimes this will take you to detailed pages, which should not be relied on out of context. We strongly recommend that you press the menu button to see the context before reading particular pages.

Summaries of the main rules

The sections on loan relationships, derivative contracts, foreign exchange and corporate interest restriction each contain overviews of the key features of the rules on those subjects. These summaries may be all you need to refer to in straightforward cases.


The CFM contains a Glossary, which provides a brief definition of commonly used financial terms. HMRC users can access this from the ‘Glossary’ left bar button. More detailed definitions of certain terms are included within the main text of the CFM, and may be found using the Search function.


HMRC users who need advice from technical specialists should contact the relevant colleagues in BAI on subjects covered by the CFM.


From 1 April 2009 and as part of a wider programme of reforms, a new tribunal service was created. Any references in this guidance to ‘appeals’, ‘General Commissioners’, ‘Special Commissioners’, and related terms should be interpreted as references to the new tribunal service. Further guidance on the new tribunals, appeals and internal review can be found in the Appeals Reviews and Tribunals Guidance (ARTG).