INTM216600 - Controlled Foreign Companies: The CFC charge gateway chapter 9 - exemptions for profits from qualifying loan relationships: scope of the rules: contents
TIOPA10/Part 9A/Ch 9/S371IA(1) introduces Chapter 9 which provides the rules for full and 75% exemption of certain non- trading finance profits (鈥淣罢贵笔蝉鈥�) that might otherwise pass through the CFC charge gateway because they fall within Chapter 5. Chapter 9 only applies to profits that arise from qualifying loan relationships (鈥净尝搁蝉鈥�) as defined at section 371IG and limited by section 371IH and where the business premises condition at section 371DG is met. Chapter 5 in contrast can apply to all NTFPs of the CFC.