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HMRC internal manual

Corporate Finance Manual

Introduction to the Corporate Finance Manual: converting from the old Corporate Finance Manual

The old and the new Corporate Finance Manuals: origins and destinations

The CFM was first introduced in 2002. It has been rewritten as a consequence of the introduction of the Corporation Tax Act 2009 (CTA09), which was part of the Tax Law Rewrite (TLR) project. The rewritten legislation follows a different structure to the predecessor legislation but like other TLR legislation, it does not change the law. Most of the content of the CFM has not changed, but it has been substantially re-ordered to reflect the structure of CTA09. There is some new material, and some of the guidance relating to older versions of the legislation has been consolidated in the last chapter of the guidance (CFM80000).

It is not practical to provide a page by page guide to show how the former guidance has been re-arranged in the new guidance. But the table below gives a general indication of the sources and destination of the guidance.

Subject Old CFM New CFM
Understanding loan relationships 3100 CFM11000
Accounting for loan relationships 4000 CFM20000
Loan relationships: scope 5050 CFM31000
Loan relationships: accounting methods (old) 5100 CFM80100
Loan relationships: IAS accounting 5144 CFM21000
Loan relationships: taxable amounts 5200 CFM33000
Loan relationships: taxing and relieving provisions 5300 CFM32000
Loan relationships: connected persons 5400 CFM35000
Loan relationships: consortia 5550 CFM35600
Loan relationships: connected persons and late interest 5600 CFM35800
Loan relationships: connected persons and discounted securities 5700 CFM37200
Loan relationships: groups 5800 CFM34000
Loan relationships: partnerships 5850 CFM36000
Loan relationships: asset-linked securities 5900 CFM82400
Loan relationships: index-linked securities 5940 CFM37100
Loan relationships: repos and stock lending 6000 CFM74100
Loan relationships: alternative finance 6050 CFM44000
Loan relationships: convertibles 6100 CFM37600
Loan relationships: non-arm’s length transactions 6200 CFM38000
Loan relationships: unallowable purposes 6210 CFM38100
Loan relationships: reset bonds 6250 CFM39040
Loan relationships: imported losses 6300 CFM33250
Loan relationships: shares as debt 6320 CFM45000
Loan relationships: money debts 6400 CFM41000
Loan relationships: structured finance 6750 CFM73000
Loan relationships: amounts not recognised by accounting practice 6900 CFM33120
Understanding forex 7002 CFM12000
Accounting for forex 8000 CFM26000
Taxing forex 9000 CFM60000
Understanding derivatives 11005 CFM13000
Accounting for derivatives 12000 CFM24000
Derivatives introduction 13000 CFM50020
Derivatives: scope 13050 CFM50300
Derivatives: accounting test 13078 CFM50200
Derivatives: underlying subject matter 13094 CFM50500
Derivatives: exclusions 13130 CFM50700
Derivatives: pre 2004 rules 13150 CFM84000
Derivatives: post 2004 rules 13250 CFM51000
Derivatives: hedging and ‘disregard’ regulations 13270 CFM57000
Derivatives: bringing amounts into account 13500 CFM51000
Derivatives: special types of contract 13530 CFM55000
Derivatives: group transfers 13630 CFM53000
Derivatives: anti-avoidance 13660 CFM56000
Derivatives: transitional rules 13700 CFM80000
Collectives 14000 CFM43000
International accounting standards 16000 CFM21000
Change of accounting practice regulations 16500 CFM76060
Artificial payments of interest 17005 CFM39020
Funding bonds 17030 CFM37400
Stock loans 17050 CFM74100
Manufactured payments 17300 CFM74300
Manufactured overseas dividends 17360 CFM74360
Repos 17500 CFM46100
Securitisation 20000 CFM72000