INTM203610 - Controlled Foreign Companies: The CFC Charge Gateway Chapter 5 - Non-trading finance profits: Capital investment from the UK: Profits pass through the CFC charge gateway once
If profits potentially pass through the CFC charge gateway under one or more of TIOPA10/S371EB to S371EE, the profits only pass through once. In the unlikely event that say out of non-trading finance profits of 拢20m, 拢3m of those profits arise from UK capital investment and 拢2m of those profits are attributable to UK SPFs in respect of the loans arising from UK capital investment, then 拢3m of the profits would pass through the CFC charge gateway under Chapter 5.