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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
Embedded image converted to link to allow page to publish on GOV.UK

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: accounting periods beginning before 1 January 2013
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.

published amendments

Debt cap: overview: introduction
Version following 2018 review
Debt cap: overview: scope of the guidance
Version following 2018 review
Updated following the 2018 CFM review

published amendments

Debt cap: gateway test: definition of relevant liabilities - finance leases and ‘quasi loans’
Version following 2018 review
Debt Cap: gateway test: definition of relevant liabilities: UK permanent establishments
Version following 2018 review
Debt cap: gateway test: definition of relevant liabilities - short and long term borrowings
Version following 2018 review
Debt cap: gateway test: calculation of worldwide gross debt
Version following 2018 review
Version following 2018 review
Debt cap: gateway test: de minimis limit
Version following 2018 review
Debt cap: gateway test: UK net debt derived from financial statements of group companies
Version following 2018 review
Version following 2018 review
Version following 2018 review
Debt cap: gateway test: group does not prepare consolidated financial statements
Version following 2018 review
Debt cap: gateway test: worldwide gross debt derived from group consolidated financial statements
Version following 2018 review
Debt cap: gateway test: the accounting periods of companies joining or leaving a group
Version following 2018 review
Debt cap: gateway test: group companies with different accounting periods to that of the worldwide group
Version following 2018 review
Debt cap: gateway test: UK permanent establishments
Version following 2018 review
Debt cap: gateway test: UK net debt derived from financial statements of group companies
Version following 2018 review
Debt cap: gateway test: test based around period of account of the worldwide group
Version following 2018 review
Debt Cap Gateway test: CTSA returns
Version following 2018 review
Debt cap: gateway test: introduction
Version following 2018 review
Debt cap: group accounts: groups merging and de-merging: de-merger examples
Version following 2018 review
Debt cap: group accounts: groups merging and de-merging: merger examples
Version following 2018 review
Version following 2018 review
Version following 2018 review
Debt cap: group accounts: groups merging and de-merging
Version following 2018 review
Version following 2018 review
Debt cap: group accounts: deriving amounts from consolidated financial statements
Version following 2018 review
Debt cap: group accounts: no consolidated financial statements prepared
Version following 2018 review
Debt cap: group accounts: financial statements not acceptable
Version following 2018 review
Debt cap: group accounts: acceptable financial statements
Version following 2018 review
Debt cap: group accounts: the importance of accounting policies
Version following 2018 review
Debt cap: group accounts: consolidated financial statements
Version following 2018 review
Debt cap: group accounts: introduction
Version following 2018 review
Debt cap: groups affected: dual listed groups
Version following 2018 review
Debt cap: groups affected: groups with stapled stock
Version following 2018 review
Debt cap; groups affected; meaning of 'relevant non-corporate entity'
Version following 2018 review
Debt cap: groups affected: meaning of 'corporate entity'
Version following 2018 review
Debt cap: groups affected: collective investment schemes
Version following 2018 review
Debt cap: groups affected: meaning of 'ultimate parent'
Version following 2018 review
Debt cap: groups affected; meaning of a group
Version following 2018 review
Debt cap: groups affected: UK group companies
Version following 2018 review
Debt cap: groups affected: relevant group companies
Version following 2018 review
Debt cap: groups affected: EU definitions
Version following 2018 review
Debt cap: groups affected: 'large groups'
Version following 2018 review
Debt cap: groups affected: introduction
Version following 2018 review
Debt cap: overview: getting help and advice
Version following 2018 review
Debt cap: overview: anti-forestalling rule
This guidance applies to worldwide group periods of account ending before or straddling 1 April 2017.
Version following 2018 review
Debt cap: overview: commencement
Version following 2018 review
Debt cap: overview: summary of the debt cap rules
Version following 2018 review
Debt cap: overview: legislation
Version following 2018 review
Debt cap: overview: international accounting standards
Version following 2018 review
Debt cap: overview: background to the debt cap
Version following 2018 review

published amendments

Debt cap: appointment of the authorised company: initial appointment and continued effect
Update following 2018 review
Debt cap: appointment of the authorised company: required information
Update following 2018 review
Debt cap: appointment of the authorised company: appointment to cover both statements
Updated following 2018 review
Debt cap: appointment of the authorised company: acting on behalf of group companies
Updated following 2018 review
Debt cap: appointment of the authorised company: appointment of an authorised company for allocating exemptions
Updated following 2018 review
Debt cap: appointment of the authorised company: appointing an authorised company for allocating disallowances
updated following 2018 review
Debt cap: appointment of the authorised company: outline
Updated following 2018 review
Debt cap: introduction to allocating the disallowance and exemption: balancing payments
Update following 2018 review
Debt cap: introduction to allocating the disallowance and exemption: no disallowance needed
Update following 2018 review
Debt cap: introduction to allocating the disallowance and exemption: interaction with CTSA
Update following 2018 review
Debt cap: introduction to allocating the disallowance and exemption: who can sign on behalf of a group company
updated following 2018 review
Debt cap: introduction to allocating the disallowance and exemption: who makes the statements?
Updated following 2018 review
Debt cap: introduction to allocating the disallowance and exemption: time limit
Updated following 2018 review
Debt cap: introduction to allocating the disallowance and exemption: outline
Updated following 2018 review
Debt cap: calculating the exemption of financing income amounts: examples
Update following 2018 review
Debt cap: calculating the exemption of financing income amounts: UK group companies joining or leaving the group
Updated following 2018 review
Debt cap: calculating the exemption of financing income amounts: UK group companies with different accounting periods
Updated following 2018 review
Updated following 2018 review
Debt cap: calculating the exemption of financing income amounts: election under section 331ZA
Update following 2018 review
Debt cap: calculating the exemption of financing income amounts: de minimis amount
Updates following 2018 review
Debt cap: calculating the exemption of financing income amounts: financing income of a UK group company
Update following 2018 review
Debt cap: calculating the exemption of financing income amounts: tested income amount
Update following 2018 review
Debt cap: calculating the exemption of financing income amounts: introduction
Updated following 2018 review
Debt cap: financial services groups: income statement of a financial services group: example
Updated following 2018 review
Debt cap: financial services groups: trading income of UK group companies
Update following 2018 review
Debt cap: financial services groups: trading income of a worldwide group
Updated following 2018 review
Debt cap: financial services groups: dealing in financial instruments
Updated following 2018 review
Debt cap: financial services groups: Lloyd’s
Update following 2018 review
Debt cap: financial services groups: insurance related activities
Update following 2018 review
Debt cap: financial services groups: insurance activities
Updated Following 2018 review
Updated following 2018 review
Debt cap: financial services groups: activities ancillary to lending activities
Update following 2018 review
Debt cap: financial services groups: lending activities
Updates following 2018 review
Debt cap: financial services groups: qualifying activities
Update following 2018 review
Debt cap: financial services groups: the meaning of ‘substantially all’
Updated following 2018 review
Debt cap: financial services groups: dealing with group companies which are not members of the group for the whole period of account
Updates following 2018 review
Debt cap: financial services groups: qualification affected by losses on activities normally reported on a net basis
Updated following 2018 review
Debt cap: financial services groups: qualification based on business activities of the worldwide group or the group companies
Updated following 2018 review
Debt cap: financial services groups: qualification test based on income from business activities
Version following 2018 review
Debt cap: financial services groups: introduction
Version following 2018 review
Debt cap: gateway test: application of the gateway test: examples
Version following 2018 review
Debt cap: gateway test: calculation of gateway test using the presentation currency of the group
Version following 2018 review
Debt cap: gateway test: definition of relevant assets
Version following 2018 review

published amendments

Debt cap: statement of allocation: groups with dual resident investing companies
updated following 2018 review
Debt cap: statement of allocation: required information for disallowance
changes following 2018 review
Debt cap: statement of allocation: outline for disallowance statements
Updated following 2018 review
Debt cap: appointment of the authorised company: when the appointment will not be accepted
updated following 2018 review
Debt cap: appointment of the authorised company: companies leaving and joining
updated following 2018 review
Debt cap: appointment of the authorised company: revocation
Updated following 2018 review

published amendments

Debt cap: failure to make statements of allocation: default allocation of disallowance for company with multiple financing expense amounts: example
updated following 2018 review
Debt cap: failure to make statements of allocation: default allocation of disallowance for company with multiple financing expense amounts
updated following 2018 review
Debt cap: failure to make statements of allocation: election for allocation of disallowance for company with multiple financing expense amounts
updated during 2018 review
Debt cap: failure to make statements of allocation: default allocation of disallowance of financing expense amounts: DRICs: example
updated following 2018 review
Debt cap: failure to make statements of allocation: default allocation of disallowance of financing expense amounts: DRICs: formulae
Updated following 2018 review
Debt cap: failure to make statements of allocation: default allocation of disallowance of financing expense amounts: DRICs involved
updated following 2018 review
Debt cap: failure to make statements of allocation: default allocation of disallowance of financing expense amounts: no DRICs
updated following 2018 review
Debt cap: failure to make statements of allocation: outline
updated following 2018 review
Debt cap: statement of allocation: obvious error or omission
updated following 2018 review
Debt cap: statement of allocation: revised statement and CTSA returns
updated following 2018 review
Debt cap: statement of allocation: late submission of revised statement: examples
updated following 2018 review
Debt cap: statement of allocation: late submission of revised statement: condition A
updated following 2018 review
Debt cap: statement of allocation: late submission of the revised statement: conditions A and B
updated following 2018 review
Debt cap: statement of allocation: submission of revised statement
Updated following 2018 review
Debt cap: statement of allocation: late submission of initial statement
updated following 2018 review
Debt cap: statement of allocation: submission of initial statement
updated following 2018 review
Debt cap: statement of allocation: joint statement
updated following 2018 review
Debt cap: statement of allocation: information accompanying the statement
updated following 2018 review
Debt cap: statement of allocation: required information for exemptions
updated following 2018 review
Debt cap: statement of allocation: outline for exemption statements
updated following 2018 review
Debt cap: statement of allocation: groups with dual resident investing companies
updated following 2018 review

published amendments

Debt cap: failure to make statements of allocation: default allocation of disallowance of financing expense amounts: DRICs: example
Minor change to fix table formatting
table align edit
table alignment fix
Update following 2018 review - correcting of table display
Debt cap: stranded reliefs: management expenses - example
updated following 2018 review
Debt cap: stranded reliefs: management expenses
updated following 2018 review
Debt cap: stranded reliefs: NTLR deficits - example
updated following 2018 review
Debt cap: stranded reliefs: non-trading loan relationship deficits
updated following 2018 review
Debt cap: stranded reliefs: introduction
Updated following 2018 review
Debt cap: intra-group short-term debt: anti-avoidance rule
updated following 2018 review
Debt cap: intra-group short-term debt: examples of arrangements without a long-term funding purpose
Updated following 2018 review
Debt cap: intra-group short-term debt: examples of long-term funding purpose
updated following 2018 review
Debt cap: intra-group short-term debt: finance arrangements with a long-term funding purpose
updated following 2018 review
Debt cap: intra-group short-term debt: long-term aggregated loan relationships
updated following 2018 review
Debt cap: intra-group short-term debt: revolving loan accounts
updated following 2018 review
Debt cap: intra-group short-term debt: example of practical application
updated following 2018 review
test update
Debt cap: intra-group short-term debt: debts with no defined repayment date
updated following 2018 review
Debt cap: intra-group short-term debt: loans and money debts with a fixed term
updated following 2018 review
Debt cap: intra-group short-term debt: what is a short-term finance arrangement?
updated following 2018 review
Debt cap: intra-group short-term debt: example of the effects of sections 319 and 320
updated following 2018 review
Debt cap: intra-group short-term debt: corresponding exclusion of finance income
updated following 2018 review
Debt cap: intra-group short-term debt: excluding finance expenses
updated following 2018 review
Debt cap: intra-group short-term debt: introduction
updated following 2018 review
Debt cap: failure to make statements of allocation: circumstances when a group company can make an amended return
updated following 2018 review
Debt cap: failure to make statements of allocation: information not provided to group companies
Updated following 2018 review
Debt cap: failure to make statements of allocation: worldwide group with more than one ultimate UK parent
updated following 2018 review
Debt cap: failure to make statements of allocation: provision of information to group companies
updated following 2018 review
Debt cap: failure to make statements of allocation: default treatment of exemption of financing income amounts: example
Updated following 2018 review
Debt cap: failure to make statements of allocation: default treatment of financing income amounts
Updated following 2018 review

published amendments

Debt cap: interaction with other rules: tax arbitrage
updated following 2018 revirw
updated following 2018 review
Debt cap: interaction with other rules: controlled foreign companies: accounting periods beginning before 1 January 2013
updated following 2018 review
Debt cap: interaction with other rules: transfer pricing
updated following 2018 review
Debt cap: interaction with other rules: late payment of interest - transitional provision
updated following 2018 review
Debt cap: interaction with other rules: deduction of tax
updated following 2018 review
Debt cap: particular types of company: educational and public bodies
updated following 2018 review
Debt cap: particular types of company: charities
updated following 2018 review
updated during 2018 review
Debt cap: particular types of company: industrial and provident societies
Updated following 2018 review
Debt cap: particular types of company: oil extraction activities
updated following 2018 review
Debt cap: particular types of company: real estate investment trusts
updated following 2018 review
Debt cap: particular types of company: group treasury companies: treasury activities
updated following 2018 review
Debt cap: particular types of company: group treasury companies: periods of account beginning before11 December 2012
fix style
Updated following 2018 review
Debt cap: particular types of company: group treasury companies: periods of account beginning on or after 11 December 2012
update following 2018 review
updated following 2018 review
Debt cap: particular types of company: exemption for group treasury companies
updated following 2018 review
Debt cap: particular types of company: definition of dormant company
updated following 2018 review
Debt cap: particular types of company: introduction
Updated following 2018 review
Debt Cap: the available amount: subsidiaries that are not consolidated
updated following 2018 review
new page content added following 2018 review
Debt Cap: the available amount: employer asset-backed pension contribution mismatches
new page added following 2018 review
Debt cap: available amount: contents
added page
page added following 2018 update
add new page to contents
Debt Cap: the available amount: partnerships
addition of new page content following 2018 review
Debt Cap: the available amount: debt restructuring mismatches
Updated following 2018 review
Debt Cap: the available amount: embedded derivatives
updated following 2018 review
Debt Cap: the available amount: DDS mismatches
updated following 2018 review
Debt Cap: the available amount: late interest mismatches
updated following 2018 review
Debt Cap: the available amount: conditions for fair value mismatches
updated following 2018 review
Debt Cap: the available amount: fair value mismatches
updated following 2018 review
Debt Cap: the available Amount: the mismatch regulations
updated following 2018 review
Debt Cap: the available amount: regulations on repos and quasi repos
updated following 2018 review
Debt Cap: the available amount: regulations on money debt and manufactured payments
updated following 2018 review
Debt cap: the available amount: the Available Amount Regulations
changes following 2018 review
Debt Cap: the available amount: exclusions from the available amount - property income
update following 2018 review
Debt Cap: the available amount: exclusions from the available amount - shipping
updated following 2018 review
Debt Cap: the available amount: exclusions from the available amount - oil
updated following 2018 review
Debt cap: the available amount: dividends treated as borrowing costs for accounting purposes
updated following 2018 review
Debt cap: the available amount: capitalised finance expenses in the consolidated financial statements
updated following 2018 review
Debt cap: the available amount: alternative finance arrangements
updated following 2018 review
Debt cap: the available amount: ancillary and financing expenses
updated following 2018 review
Debt cap: the available amount: debt linked to an index
updated following 2018 review
Debt Cap: the available amount: amortising discount and premium
updated following 2018 review
Debt cap: the available amount: finance expenses included in the available amount
updated following 2018 review
Debt cap: the available amount: definition of the available amount
updated following 2018 review
Debt cap: the available amount: introduction
updated following 2018 review

published amendments

Anti-avoidance rules - contents
pages added following 2018 review
Debt cap: anti-avoidance rules: main rules: non-abusive schemes: examples
updated following 2018 review
Debt cap: anti-avoidance rules: main rules: particular avoidance: examples
updated following 2018 review
Debt cap: anti-avoidance rules: EEA financing income: effect of anti-avoidance rules applying
updated following 2018 review
Debt cap: anti-avoidance rules: main rules: calculating the counter factual: examples
updated following 2018 review
Debt cap: anti-avoidance rules: EEA financing income: conditions for anti-avoidance rules to apply
updated following 2018 review
Debt cap: anti-avoidance rules: main rules: calculating the counterfactual
updated following 2018 review
Debt cap: anti-avoidance rules: EEA financing income: non-abusive schemes: examples
updated following 2018 review
Debt cap: anti-avoidance rules: main rules: effect of anti-avoidance rules applying
updated following 2018 review
Debt cap: anti-avoidance rules: EEA financing income: particular avoidance: examples
updated following 2018 review
Debt cap: anti-avoidance rules: main rules: Condition B - losses of UK companies
updated following 2018 review
Debt cap: anti-avoidance rules: EEA financing income: excluded schemes
updated following 2018 review
Debt cap: anti-avoidance rules: main rules: Condition B - sum of profits of UK companies
updated following 2018 review
Debt Cap: anti-avoidance rules: main rules: excluded schemes: de minimis amount
updated following 2018 review
Debt cap: anti-avoidance rules: main rules: comparing net relevant deductions: examples
updated following 2018 review
Debt cap: anti-avoidance rules: main rules: meaning of ‘relevant net deduction’
updated following 2018 review
Debt cap: anti-avoidance rules: main rules: excluded schemes: general
fixed formatting
updated following 2018 review
Debt cap: anti-avoidance rules: main rules: conditions for anti-avoidance rules to apply
Updated following 2018 review
Debt cap: anti-avoidance rules: main rules: scope for avoidance
updated following 2018 review
Debt cap: anti-avoidance rules: gateway: excluded schemes
Updated following 2018 review
Debt cap: anti-avoidance rules: financial services exclusion and anti-avoidance rules
updated following 2018 review
Debt cap: anti-avoidance rules: gateway: effect of anti-avoidance rules applying
updated following 2018 review
Debt cap: anti-avoidance rules: gateway: non-abusive schemes
updated following 2018 review
Debt cap: anti-avoidance rules: gateway: conditions for anti-avoidance rules to apply
updated following 2018 review
Debt cap: anti-avoidance rules: gateway: examples of particular avoidance
updated following 2018 review
Debt cap: anti-avoidance rules: general: requests for clearances
updated following 2018 review
Debt cap: anti-avoidance rules: general: excluded schemes
updated following 2018 review
updated following 2018 review
Debt cap: anti-avoidance rules: general: change in purpose and whether there is a new scheme to consider
updated following 2018 review
Debt cap: anti-avoidance rules: general: when the purpose test is applied
updated following 2018 review
Debt cap: anti-avoidance rules: general: UK company is not party to particular transactions
updated following 2018 review
Debt cap: anti-avoidance rules: general: main purpose test
updated following 2018 review
Debt cap: anti-avoidance rules: general: schemes in place before commencement date
updated following 2018 review
Debt cap: anti-avoidance rules: general: scheme as part of a wider scheme
updated following 2018 review
Debt cap: anti-avoidance rules: general: definition of a scheme
updated following 2018 review
Debt cap: anti-avoidance rules: introduction
updated following 2018 review
Debt cap: income from EEA group companies: interaction with double taxation agreements
updated following 2018 review
Debt cap: income from EEA group companies: when to test
updated following 2018 review
Debt cap: income from EEA group companies: qualifying EEA tax relief available for future period of account
updated following 2018 review
Debt cap: income from EEA group companies: 'all steps taken'
Updated following 2018 review
Debt cap: income from EEA group companies: qualifying EEA tax relief given in current or previous period of account
updated following 2018 review
Debt cap: income from EEA group companies: qualifying EEA tax relief
updated following 2018 review
Debt cap: income from EEA group companies: payer is liable to tax
updated following 2018 review
Debt cap: income from EEA group companies: payer is EEA PE of non-EEA resident company
updated following 2018 review
Debt cap: income from EEA group companies: payer is tax resident in an EEA territory
updated following 2018 review
Debt cap: income from EEA group companies: payer is a relevant associate of recipient
Updated following 2018 review
Debt cap: income from EEA group companies: conditions to be met
updated following 2018 review
Debt cap: income from EEA group companies: priority of application
updated following 2018 review
Debt cap: income from EEA group companies: financing income amounts potentially involved
updated following 2018 review
Debt cap: income from EEA group companies: introduction
updated following 2018 review
Debt cap: interaction with other rules: Corporate Interest Restriction: Periods of account straddling 1 April 2017
added following 2018 review
Debt cap: interaction with other rules: controlled foreign companies - CFC accounting periods beginning on or after 1 January 2013
added following 2018 revieew
Debt cap:interaction with other rules:Hybrid Mismatch
correct link
added following 2018 review
Debt cap: interaction with other rules: Contents
updated following 2018 review
addition of new pages CFM93045, CFM 93055, CFM93060 following 2018 review

published amendments

Understanding corporate finance: derivative contracts: options: how options work
format error correction

published amendments

Interest restriction
section added
fix for inserting into top contents
Interest restriction: overview
update contents list