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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: Full Exemption - Qualifying Resources: contents


The aim of the qualifying resources rule is to give full exemption for non-trading finance profits (NTFPs - INTM203000) of a qualifying loan relationship (“QLR” - INTM217000) that is funded in a way that places no demands on group resources outside the borrower’s own jurisdiction and falls within certain conditions outlined in the rules.

Qualifying sources of funding are broadly:

  • funding from group profits arising in the borrower’s territory;
  • funds raised by issuing shares from the group’s top company.

Note that each QLR is considered separately.