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HMRC internal manual

International Manual

HM Revenue & Customs
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Controlled Foreign Companies: The CFC Charge Gateway Chapter 3 - Determining which (if any) of Chapters 4 to 8 apply: Does Chapter 6 apply?: contents

Does Chapter 6 apply?

Chapter 6 (trading finance profits) applies for a CFC’s accounting period only if the CFC has trading finance profits and at any time during the accounting period it has funds or other assets derived directly or indirectly from UK connected capital contributions (see INTM198050).

See INTM248450 for a full definition of trading finance profits, but broadly they are profits arising from loan relationships, derivative contracts or company distributions that are included in a trade profits computation.