[49A Limit on credit in cases involving qualifying loan relationships of CFCs]
Taxation (International and Other Provisions) Act 2010 (2010 c 8) | Legislation

[49A  Limit on credit in cases involving qualifying loan relationships of CFCs]

[(1)     This section applies if—

(a)     a claim is made under Chapter 9 of Part 9A (controlled foreign companies: exemptions for profits from qualifying loan relationships) in relation to an accounting period (“the relevant period”) of a CFC (“the creditor CFC”),

(b)     in the relevant period, the creditor CFC has a qualifying loan relationship in relation to which another CFC is the ultimate debtor by virtue of section 371IG(4) or (5), and

(c)     a UK resident company (“the relevant UK company”) has loan relationship credits which arise in the relevant period from—

(i)     loan B (see section 371IG(3)(b)), or

(ii)     loans out of which loan B is wholly or partly funded (directly or indirectly).

(2)

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