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HMRC internal manual

International Manual

From
HM Revenue & Customs
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Controlled Foreign Companies: The CFC Charge Gateway Chapter 5 - Non-trading finance profits: Capital investment from the UK: Profits pass through the CFC charge gateway once

If profits potentially pass through the CFC charge gateway under one or more of TIOPA10/S371EB to S371EE, the profits only pass through once. In the unlikely event that say out of non-trading finance profits of £20m, £3m of those profits arise from UK capital investment and £2m of those profits are attributable to UK SPFs in respect of the loans arising from UK capital investment, then £3m of the profits would pass through the CFC charge gateway under Chapter 5.