INTM218700 - Controlled Foreign Companies: »Ê¹ÚÌåÓýapp CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: Full Exemption - Qualifying Resources: contents

Aim

»Ê¹ÚÌåÓýapp aim of the qualifying resources rule is to give full exemption for non-trading finance profits (NTFPs - INTM203000) of a qualifying loan relationship (“QLRâ€� - INTM217000) that is funded in a way that places no demands on group resources outside the borrower’s own jurisdiction and falls within certain conditions outlined in the rules.

Qualifying sources of funding are broadly:

  • funding from group profits arising in the borrower’s territory;
  • funds raised by issuing shares from the group’s top company.

Note that each QLR is considered separately.

  1. INTM218750
    What are Qualifying Resources?: contents
  2. INTM218950
    Claims for Qualifying Resources: contents