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HMRC internal manual

International Manual

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HM Revenue & Customs
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Controlled Foreign Companies: The CFC Charge Gateway Chapter 5 - Non-trading finance profits: UK Activities: Calculation of Chapter 5 profits

TIOPA10/S371DB(1) Step 7

The CFC’s non-trading finance profits are re-determined in accordance with step 7 by omitting assets and risks attributed to the assumed UK permanent establishment of the CFC. The non-trading finance profits passing through the CFC charge gateway under Chapter 5 are those profits that are as a consequence left out of the CFC’s re-determined profits.