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HMRC internal manual

International Manual

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Controlled Foreign Companies: The CFC charge gateway chapter 9 - exemptions for profits from qualifying loan relationships: what is a qualifying loan relationship: the ultimate debtor rule - detailed application: contents

The “ultimate debtor” condition ensures that a qualifying loan relationship is defined by reference to who, in substance, the real borrower is. TIOPA10/Part 9A/S371IG(2) provides that the ultimate debtor is the immediate debtor in relation to a qualifying loan relationship (“QLR” - INTM217000) unless section 371IG(3) applies to look through any conduit type arrangements