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HMRC internal manual

Corporate Finance Manual

Updates: Corporate Finance Manual

2016

published amendments

Debt cap: overview: scope of the guidance
Stylistic changes and owner updated

published amendments

Loan relationships: computational rules: credits and debits not brought into account: revaluation
Test Jim Wager 9/5/16. Full stop after title

published amendments

Derivative contracts: relevant contracts: contracts for differences
Legislative reference updated

published amendments

Other tax rules on corporate finance: stock loans and manufactured payments: overview
Link updated

published amendments

Loan relationships: partnerships: company partners and connected debtors: definition of ‘connection’ and ‘major interest’
Grammar corrected

2017

published amendments

Foreign exchange: tax rules on exchange gains and losses: loan relationships and derivative contracts: connected parties
Examples updated to reflect change in accounting treatment.

published amendments

Loan relationships: connected parties: late interest: APs beginning on or after 1 April 2009
Link updated

published amendments

Other tax rules on corporate debt: group mismatch schemes: the conditions
Minor clarification

published amendments

Other tax rules on corporate debt: group mismatch schemes: meaning of relevant tax advantage
Link to CFM 77610 added.

published amendments

Introduction to the Corporate Finance Manual: contents
Previous glossary added to CFM

published amendments

Other tax rules on corporate debt: group mismatch schemes: overview
Minor clarification on effect of GMS rules.

published amendments

Other tax rules on corporate debt: group mismatch schemes: application of the conditions
Minor changes to clarify that tests are not necessarily just carried out at the outset of a scheme.
Understanding corporate finance: derivative contracts: swaps
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published amendments

Loan relationships: special types of security: funding bonds: processing a repayment claim that is to be satisfied by funding bond
Funding Bond Section address updated.
Loan relationships: special types of security: funding bonds: paying the funding bonds to HMRC
Registered office of RN Ltd updated.

2018

published amendments

Derivative contracts: group continuity: European matters
Change of CRM to CCM requested by Sonam Sony
Loan relationships: group continuity: the European Mergers Tax Directive
Change of CRM to CCM requested by Sonam Sony
Debt cap: appointment of the authorised company: initial appointment and continued effect
Change of CRM to CCM requested by Sonam Sony
Debt cap: introduction to allocating the disallowance and exemption: no disallowance needed
Change of CRM to CCM requested by Sonam Sony
Debt cap: anti-avoidance rules: general: requests for clearances
Change of CRM to CCM requested by Sonam Sony
Debt cap: interaction with other rules: controlled foreign companies
Change of CRM to CCM requested by Sonam Sony

published amendments

Other tax rules on corporate finance: exemptions from loan relationships: savings certificates
References to CTA 09 corrected.