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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 9 - exemptions for profits from qualifying loan relationships: scope of the rules: contents

TIOPA10/Part 9A/Ch 9/S371IA(1) introduces Chapter 9 which provides the rules for full and 75% exemption of certain non- trading finance profits (“NTFPs”) that might otherwise pass through the CFC charge gateway because they fall within Chapter 5. Chapter 9 only applies to profits that arise from qualifying loan relationships (“QLRs”) as defined at section 371IG and limited by section 371IH and where the business premises condition at section 371DG is met. Chapter 5 in contrast can apply to all NTFPs of the CFC.