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HMRC internal manual

International Manual

Controlled Foreign Companies: The CFC Charge Gateway Chapter 3 - Determining which (if any) of Chapters 4 to 8 apply: Does Chapter 6 apply?: Funds or other assets derived directly/indirectly from UK connected capital contributions

UK connected capital contributions are defined as any capital contribution to the CFC made (directly or indirectly) to the CFC by a UK resident company connected with the CFC (whether in relation to an issue of shares in the CFC or otherwise). See INTM248100.

A capital contribution can be in kind or in cash and can involve the issuance of shares or not. However, it will not include a situation where a liability to repay the capital contribution (e.g. by recognising a loan or other future obligation) arises when it is made, provided the contribution gives rise to taxable credits for the UK resident company that made it.