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    1. Home
    HMRC internal manual

    International Manual

    From:
    HM Revenue & Customs
    Published
    9 April 2016
    Updated:
    16 May 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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