Beta This part of GOV.UK is being rebuilt – find out what this means

HMRC internal manual

International Manual

From
HM Revenue & Customs
Updated
, see all updates

Controlled Foreign Companies: The CFC charge gateway chapter 9 - exemptions for profits from qualifying loan relationships: scope of the rules: chapter 9 and double taxation relief

For TIOPA10/Part 9A/Chapter 9 purposes double tax relief will be proportionate to the profits that are subject to tax in the UK in accordance with Chapter 16.

Use this link to see example