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HMRC internal manual

Corporate Finance Manual

Other tax rules on corporate debt: group mismatch schemes: other specific instances

Trading Income

CTA10/S938K clarifies that references to amounts being brought into account under Part 5 or Part 7 include amounts that are, or are not, brought into account under Part 3 as expenses or receipts of a trade by virtue of CTA09/S297 (trading loan relationship debits) or CTA09/S573 (trading derivative contract debits).

Controlled Foreign Companies

The GMS is generally confined to UK to UK asymmetries, but will also apply where one or more of the parties to a GMS is a CFC. In addition, normal de minimis rules for determining whether a CFC has apportionable profits is disapplied where the CFC is party to a GMS.

Unallowable Purpose

CTA10/S938N ensures that in determining whether any amounts are brought into account apart from the group mismatch rules (and so might give rise to a relevant tax advantage), existing unallowable purpose rules are to be treated as of no effect.

It follows that the group mismatch rules apply in priority to unallowable purpose rules.