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

HMRC internal manual

International Manual

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: Arrangements involving equity instruments

The look through provisions are not restricted to cases where funds are passed by way of loans. TIOPA10/Part 9A/S371IG(3) refers to loans that are used to fund (directly or indirectly) other loans, but does not provide any restriction on the form of that funding. Funds might be provided using an arrangement that involves an equity investment.

Use this link to view example