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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: What is a Qualifying Loan Relationship: The Ultimate Debtor Rule - Detailed Application: Loans made to acquire an existing loan

Funding a loan for the purposes of the ultimate debtor rule includes lending money to another company for the second company to acquire an existing loan.

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