A chargeable company (D4.439) may make a claim for exemption of certain intra-group non-trading finance profits that would otherwise pass through the CFC charge gateway because they fall within Chapter 5 (non-tading finance profits, see D4.427). In order to make this claim the profits must arise from qualifying loan relationships and the business premises condition at TIOPA 2010, s 371DG (D4.426) must also be met1.
In order to comply with the EU requirements of the Anti Tax Avoidance Directive (EU 2016/1164), Finance Act 2019, s 20 amended the definition of qualifying loan relationship profits which would be covered by this exemption2. For CFC accounting periods beginning on or after 1 January 2019, the profits eligible for the exemption are non-trading finance profits from all the CFC's qualifying loan relationships taken together which:
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•ÌýÌýÌýÌý fall within TIOPA 2010, s 371EC of Chapter 5 (capital investment from the UK), and
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•ÌýÌýÌýÌý do not fall within TIOPA 2010, s 371EB of Chapter 5 (UK activities).
So the profits eligible
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