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

  • TIOPA10/Part 9A/Ch 9/S371IA(9) excludes from a CFC charge under Chapter 9 any non- trading finance profits (“NTFPs”) where they:
  • arise from the investment of funds held by the CFC for trading purposes;
  • arise from the investment of funds held by the CFC for the purposes of a property business;
  • fall within Chapter 8 (solo consolidation - INTM213000);
  • arise from a relevant finance lease - INTM248600.