Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: Full Exemption - Qualifying Resources: What are Qualifying Resources?: contents
Qualifying resources are defined by reference to the borrower’s territory: this is called the ‘relevant territory’ and must be identified before it is possible to determine whether resources are qualifying resources. In outline, the categories of qualifying resource are:
- profits from lending to the territory;
- profits earned in the territory;
- Qualifying Resources arising from shares issued by the group top company;
- share for share exchanges;
- funds derived from share issues.