[371IB Loans funded out of qualifying resources]
Taxation (International and Other Provisions) Act 2010 (2010 c 8) | Legislation

[371IB  Loans funded out of qualifying resources]

[(1)     This section applies to a qualifying loan relationship if company C's claim under this Chapter states that this section is to apply to the qualifying loan relationship.

(2)     X% of the profits of the qualifying loan relationship are exempt if company C's claim establishes—

(a)     that, at all times during the relevant period, at least X% of the principal outstanding on the relevant loan (as that may vary from time to time during the relevant period) is funded by the CFC wholly out of qualifying resources, and

(b)     that the ultimate debtor in relation to the qualifying loan relationship (see section 371IG(2) to (7)) is resident at all times during the relevant period in one territory only and that its territory of residence does not change at any time during the relevant period.

(3)     “X%” is the percentage specified in company C's claim for the purposes of this section in relation to the qualifying loan relationship (which may be 100%).

(4)     “The relevant period” means—

(a)     the accounting period, or

(b)     if for any part of the accounting period no principal is outstanding on the relevant loan, the part of the accounting

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