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HMRC internal manual

International Manual

From
HM Revenue & Customs
Updated
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Controlled Foreign Companies: The CFC Charge Gateway Chapter 5 - Non-trading finance profits: contents

Profits pass through the CFC charge gateway at Chapter 5 broadly when non-trading finance profits are earned by CFCs from lending to other members of the multinational group and/or third parties to the extent that either the funding for the loans is provided from UK capital investment or the key management functions relating to the loans and their associated risks are undertaken by UK resident persons. Non-trading finance profits arising on lending or similar arrangements to a UK resident connected person will also pass through the CFC charge gateway at Chapter 5 in certain circumstances.