Beta This part of GOV.UK is being rebuilt – find out what this means

HMRC internal manual

International Manual

From
HM Revenue & Customs
Updated
, see all updates

Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: Full Exemption - Qualifying Resources: What are Qualifying Resources?: Categories of Qualifying Resource

This is the first section to consider when determining if resources are qualifying resources. Two types of qualifying resource are identified by this subsection:

Funds derived from shares may arise from shares held by the CFC in group companies, or from shares issued by the CFC to group companies.

Funds derived from shares are subject to conditions in TIOPA10/Part 9A/S371IB(7) and are qualifying resources only if they meet the further conditions in that subsection.