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HMRC internal manual

Corporate Finance Manual

Debt cap: calculating the exemption of financing income amounts: financing income of a UK group company

Establishing the financing income amounts

The net financing income is the sum of the relevant group company’s financing income amounts for the period less the sum of the company’s financing expense amounts for the period. Financing income amounts are defined in TIOPA10/S314 in a precisely similar way to the definition of financing expense amounts in section 313. As with financing expense amounts, there are specific exclusions in sections 316 to 327 - further detail can be found at CFM92000+.

The financing income amounts of a company for a period of account of the worldwide group is any amount that meets three conditions in TIOPA10/S314. An amount is financing income if, apart from the operation of Part 7 it would be brought into account:

  • as a trading or non-trading credit, in respect of a loan relationship (but see below for exceptions); or
  • for the purposes of corporation tax as financing income implicit in payments received under finance leases; or
  • for the purposes of corporation tax as financing income receivable on debt factoring or a similar transaction; or
  • as a guarantee fee that is received from another company

A loan relationship debit is not financing income if it is in respect of:

  • a reversal of an impairment loss; or
  • an exchange gain; or
  • a profit from a related transaction.

The guidance at CFM91040 - 91070 on the computation of financing expense amounts is also relevant (with appropriate modifications) to financing income amounts.