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HMRC internal manual

International Manual

Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: What is Excluded from the definition of a Qualifying Loan Relationship: Section 371IH(2)

Section 371IH(2)

TIOPA10/Part 9A/S371IH(2) provides that a loan cannot be a qualifying loan relationship (“QLR” - INTM217000) where the ultimate debtor is a UK resident company unless it is taken into account for the purposes of determining the profits attributable to an exempt foreign permanent establishment of the ultimate debtor, an election is made under CTA09/S18A in relation to the ultimate debtor and all the company’s debits are brought into account in determining the exemption adjustment under that section.