
CFM76048 – Corporate Finance Manual – HMRC Internal Manual
CTA09/S465B and S702 When a company holds a loan or derivative whose amounts are recognized…
CTA09/S465B and S702 When a company holds a loan or derivative whose amounts are recognized…
TIOPA10/S388 Where income is derived from a foreign jurisdiction for a UK resident company and…
TIOPA10/445 The basic election of QIC joint venture under TIOPA10/S444 applies when the joint venture…
The corporate tax charge: the formula: ‘RP’ and ‘DS’ Regulation 14(1) establishes the basis on…
TIOPA10/S461 The Corporate Interest Restriction contains an Anti-Avoidance Plan Rule (RAAR) which has the effect…
Insight Many entries in a company’s corporation tax return, in particular its trading profit, will…
What does the Corporate Finance Manual contain? The Corporate Finance Handbook begins with an explanation…
These guidelines apply to accounting periods of the company beginning on or after January 1,…
Investor taxation The main cash flows of a securitization are the claims on the securitized…
Main features of pension company taxation rules Schedule 13 of the FA 2007 introduced major…
TIOPA10/S423 The default approach for the calculation of group interest and group EBITDA is closely…
CTA09/PT5/CH8 Overview Under normal lending relationship rules, interest is exempt when accrued in accounts, not…
CTA09/S604A These guidelines apply to accounting periods of the company beginning on or after January…
The hybrid capital instrument rules apply to loan relationships that fall under a bespoke definition…
Exchange gains and losses This part of the Corporate Finance Manual deals with the taxation…
CFM70010 explains that certain tax rules relating to corporate debt are found outside the main…
Securitization Companies (Application of Article 83(1) of the Finance Act 2005: Accounting Standards) Regulations 2007…
The calculation of the group’s net interest expense (MIGN) is based on the amounts recognized…
Some companies raise funds by issuing instruments (referred to here as “hybrid capital”) that sit…
CTA10/S14, 15 Loss carry forward CTA10/S14 deals with the situation where a company, in accordance…
TIOPA 2010/S452 The Corporate Interest Restriction (CIR) applies to Real Estate Investment Trusts (REITs) and…
Example of an avoidance scheme to alleviate interest and principal Example 1: ‘plain vanilla’ loan…
CTA09/S352B Tax asymmetries can arise in situations where a company borrows externally and then lends…
TIOPA10/S440-S442 Although a company is a qualifying infrastructure company (QIC), in addition to exempting certain…
The legislative remedy: relevant effects 1 and 2 The first relevant effect, in Section 759(3),…
These guidelines apply to worldwide group accounting periods ending on or before April 1, 2017.…
TIOPA10/S452(6) to (10) Example 1 A UK REIT group has a refusal of CIR of…
F(2)A15/SCH7/PARAS120-129 The changes made to the provisions relating to derivative contracts by F(2)A15 affected not…
Many holders and issuers of convertible or exchangeable securities, or asset-linked securities, will separately account…
TIOPA/S406(5)-(7) The purpose of the calculations is to arrive at an overall tax-EBITDA figure for…
S316 (lending relationships) and S614 (derivative contracts) are the main provisions for taking into account…
SI 2004/3271: 3C regulation Certain debits and credits resulting from a change in accounting method…
Processing of warranty contracts The lender of the securities will normally require security from the…
CTA09/S607ZA Relief for pre-opening financing charges From 6 April 2020, a non-resident company which carries…
TIOPA10 / S460 (1) (c) – (d) The corporate interest restriction rules contain specific provisions…
The Treasury has adopted the Taxation of Regulatory Capital Securities Regulations 2013 (“RCS Regulations”) to…
CFA09/S330A-330C These guidelines apply to accounting periods beginning on or after January 1, 2016. Overview…
TIOPA10/S409 Where the income is not or is only partially subject to UK tax due…
Company A and company B are part of the same group. Company A issues a…
SI 2004/3271: rules 3A and 3B Amounts reported Prescribed debits and credits (see CFM76080) are…
The rules of limitation of the interest of the companies (CIR) apply to any company…
Cases in which the rules on derivative contracts do not apply The vast majority of…
CTA10 / S6, S7 Company accounts drawn up in a presentation currency other than the…
Accounting treatment IAS39 / FRS102 / FRS105 IAS39, FRS102 and [FRS105] (and formerly FRS 26)…
Interest paid in the ordinary course of banking business If a bank pays short-term interest,…
For the periods 1993 to 2004, UK GAAP rules for accounting for exchange differences were…
What are “financial assets”? CFM72380 through CFM72470 explain the definitions of the five types of…
TIOPA10 / PART10 / CH6 The function of the corporate interest restriction is to provide…
The holding company: regulation 6 The holding company must meet two conditions: its activity, apart…
Fund The Oxford English Dictionary (Compact Edition) defines “securitization” as “the conversion of an asset,…
What is the Corporate Finance Handbook? The Corporate Finance Manual (CFM) contains guidelines from HM…
These guidelines apply to worldwide group accounting periods ending on or before April 1, 2017.…
The corporate tax charge: the formula: ‘D’ D is the lesser of: the sum of…
Where an instrument meets the CTA09/S475C definition of a hybrid capital instrument, the tax rules…
TIOPA10/S406, S407 Adjusted corporation tax revenue is a company’s taxable profit or loss for an…
CTA09/S665, 666 References to a standard convertible are instruments where the holder has the option…
FA15/S25 What changes have been made? FA15/S25 limited the categories of connection to which the…
F(No.2)A17/Sch5/Para29-30 The business interest restriction applies to tax-interest and tax-EBITDA amounts. These in turn are…
Aspects of taxable gains from convertible and exchangeable securities – the holder’s perspective Securities that…
Priority rules The CIR applies after most other tax rules that may affect the calculation…
Overview This section of the Corporate Finance Handbook explains the transitional adjustments that arise for…
CTA10/S679 TIOPA10/S379 CTA10/PT14, “Change in Business Ownership” contains detailed rules that may restrict relief for…
Other tax rules Transfer price See INTM566010 for guidance on thin capitalization issues in securitization…
Commencement and termination as a securitization company A new company created from January 1, 2007…
TIOPA10/SCH7A/PARA22 Where a reporting company concludes that the total disallowed amount (TIOPA10/S373(2) for the global…
CTA09/S465B and S702 In the event of a change in the basis of accounting for…
CTA09/S320 Capitalized amounts These guidelines cover cases where interest is capitalized in a company’s financial…
Deduction for financial expenses The objective of the structured finance rules is to ensure the…