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HMRC internal manual

International Manual

HM Revenue & Customs
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Controlled Foreign Companies: Definitions for terms in Part 9A: Alphabetic index of terms defined in Part 9A: Trading finance profits

TIOPA10/S371VG(4) defines trading finance profits as any amounts included in a CFC’s assumed total profits for the accounting period which are treated as trading profits under Part 3 of CTA 2009, but that (if they were not trade profits) would be charged to tax as non-trading finance profits, as defined at INTM248400. They also include trading profits arising from a “relevant finance lease” (see INTM248600).