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HMRC internal manual

International Manual

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 Excluded from the definition of a Qualifying Loan Relationship: Section 371IH(9A) to (9E): Examples: contents

In these examples the purpose of the arrangement is stated and subsection (9A) - (9E) applied accordingly. However, in all cases it should be remembered that the tax analysis for a particular group will depend on the specific facts of that case and the actual purpose of the arrangements. This may be established by discussion with the group, but in contentious cases, may require extensive record examination