293 Controlled foreign companies: qualifying loan relationships (1)
Finance Act 2014 (2014 c 26) | Legislation

293  Controlled foreign companies: qualifying loan relationships (1)

(1)     In Chapter 9 of Part 9A of TIOPA 2010 (controlled foreign companies: qualifying loan relationships) in section 371IH (exclusions from definition of “qualifying loan relationship”) after subsection (9) insert—

“(9A)     Subsection (9B) applies to a creditor relationship of a CFC if—

(a)     a creditor relationship (“the UK creditor relationship”) of a UK connected company is made where the debtor is a non-UK resident company connected with the UK connected company,

(b)     subsequently, an arrangement (“the relevant arrangement”) is made directly or indirectly in connection with the UK creditor relationship, and

(c)

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