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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: Matched Interest Rule: Claims

TIOPA10/Part 9A/S371IJ provides that a Chapter 9 claim must be made in the UK chargeable company’s tax return for the period and sets out the time limits for the claim and for varying or withdrawing that claim. In practice the claim will be made in the corporation tax computation supporting the return rather than on the face of the return itself.

A later claim may be made, varied or withdrawn if allowed by an Officer of Revenue and Customs. A claim may also be varied or withdrawn outside of the usual time limits where there are changes to the tested income amounts and tested expense amounts, provided that the claim is made within 12 months of such a change and the claim is made to take account of that change (and not for another purpose).

Only one claim per company is required so full and partial exemption claims are made in respect of the company at the same time.