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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: The 75% Exemption

TIOPA10/Part 9A/S371ID applies to a qualifying loan relationship (“QLR” - INTM217000) where a claim has not been made under section 371IB that non-trading finance profits (“NTFPs” - INTM203000) earned from QLRs that are funded out of qualifying resources should be exempt. It provides that 75% of the profits of the QLR shall be exempt.

It is possible to make a 75% exemption claim under section 371ID in Year 2 in respect of a QLR when in Year 1 a qualifying resources claim was made under section 371IB if the facts and circumstances for making a claim change.