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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: 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.