INTM217130 - Controlled Foreign Companies: 皇冠体育app CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: What is a Qualifying Loan Relationship: 皇冠体育app Ultimate Debtor Rule - Detailed Application: Loans made to acquire an existing loan
Funding a loan for the purposes of the ultimate debtor rule includes lending money to another company for the second company to acquire an existing loan.
In the link to the example diagram below, CFC 1 lends to CFC 2 which acquires a loan to CFC P from CFC 3. CFC P has used the funds for qualifying purposes under section 371IH. P is the ultimate debtor in respect of the loan from CFC 1 to CFC 2.