»Ê¹ÚÌåÓýapp

TIOPA10/S371EA

Chapter 5 is the CFC charge gateway for non-trading finance profits for the purpose of determining the CFC charge in accordance with Chapter 2 (see in particular TIOPA10/S371BA(3)(a)). »Ê¹ÚÌåÓýapp profits are any non-trading finance profits that are included within the CFC’s assumed total profits for the accounting period, so far as they fall within any of TIOPA10/S371EB to 371EE. »Ê¹ÚÌåÓýappse sections apply where the CFC has non-trading finance profits that are derived from:

• assets and risks in relation to which any relevant significant people functions (SPFs) are carried out in the UK;
• capital investment from the UK;
• specified arrangements in lieu of dividends (typically loans) with the UK;
• UK finance leases.