INTM217100 - Controlled Foreign Companies: The CFC charge gateway chapter 9 - exemptions for profits from qualifying loan relationships: what is a qualifying loan relationship: the ultimate debtor rule - detailed application: contents

The “ultimate debtor” condition ensures that a qualifying loan relationship is defined by reference to who, in substance, the real borrower is. TIOPA10/Part 9A/S371IG(2) provides that the ultimate debtor is the immediate debtor in relation to a qualifying loan relationship (“QLR” - INTM217000) unless section 371IG(3) applies to look through any conduit type arrangements

1. INTM217110

   Loans made to fund another loan
2. INTM217120

   Arrangements involving equity investments
3. INTM217130

   Loans made to acquire an existing loan
4. INTM217140

   Loans used for more than one purpose
5. INTM217150

   Test by reference to each accounting period
6. INTM217160

   Loans to Partnerships and other transparent entities
7. INTM217170

   Loans to Banking, Insurance and Group Treasury Companies
8. INTM217180

   Interaction of amounts exempted under Chapter 9 and subsequent adjustments under Chapter 6
9. INTM217190

   Cash Pooling