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  1. Home
HMRC internal manual

International Manual

From:
HM Revenue & Customs
Published
9 April 2016
Updated:
7 April 2025 - See all updates
  1. Back to contents
  2. INTM190000
  3. INTM203000

INTM203500 - Controlled Foreign Companies: The CFC Charge Gateway Chapter 5 - Non-trading finance profits: Capital investment from the UK: contents

  1. INTM203510
    Relevant UK funds and assets
  2. INTM203520
    Example of capital investment from the UK - back to back investment from the UK via a third party
  3. INTM203530
    Example of capital investment from the UK - loans out of profits previously subject to an apportionment
  4. INTM203540
    Example of capital investment from the UK - compensating adjustment
  5. INTM203550
    Example of capital investment from the UK - transfer of an asset in consideration for the cancellation of a liability
  6. INTM203560
    Example of capital investment from the UK - earlier contribution by the parent - trading profits
  7. INTM203570
    Example of capital investment from the UK - earlier contribution by the parent - interest profits
  8. INTM203580
    Profits generated in overseas subsidiaries
  9. INTM203590
    Establishing a clear factual link on source of funding
  10. INTM203600
    UK connected company
  11. INTM203610
    Profits pass through the CFC gateway once
  12. INTM203620
    Management fee deduction
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