
CFM73160 – Corporate Finance Manual – HMRC Internal Manual
Deduction for financial expenses The objective of the structured finance rules is to ensure the…
Deduction for financial expenses The objective of the structured finance rules is to ensure the…
CTA09/S320 Capitalized amounts These guidelines cover cases where interest is capitalized in a company’s financial…
CTA09/S465B and S702 In the event of a change in the basis of accounting for…
TIOPA10/SCH7A/PARA22 Where a reporting company concludes that the total disallowed amount (TIOPA10/S373(2) for the global…
Commencement and termination as a securitization company A new company created from January 1, 2007…
Other tax rules Transfer price See INTM566010 for guidance on thin capitalization issues in securitization…
CTA10/S679 TIOPA10/S379 CTA10/PT14, “Change in Business Ownership” contains detailed rules that may restrict relief for…
These guidelines apply to worldwide group accounting periods ending on or before April 1, 2017.…
Priority rules The CIR applies after most other tax rules that may affect the calculation…
Aspects of taxable gains from convertible and exchangeable securities – the holder’s perspective Securities that…
F(No.2)A17/Sch5/Para29-30 The business interest restriction applies to tax-interest and tax-EBITDA amounts. These in turn are…
FA15/S25 What changes have been made? FA15/S25 limited the categories of connection to which the…
CTA09/S665, 666 References to a standard convertible are instruments where the holder has the option…
TIOPA10/S406, S407 Adjusted corporation tax revenue is a company’s taxable profit or loss for an…
Where an instrument meets the CTA09/S475C definition of a hybrid capital instrument, the tax rules…
The corporate tax charge: the formula: ‘D’ D is the lesser of: the sum of…
TIOPA10/S452(6) to (10) Example 1 A UK REIT group has a refusal of CIR of…
Securitization Companies (Application of Article 83(1) of the Finance Act 2005: Accounting Standards) Regulations 2007…
CFM70010 explains that certain tax rules relating to corporate debt are found outside the main…
Exchange gains and losses This part of the Corporate Finance Manual deals with the taxation…
The hybrid capital instrument rules apply to loan relationships that fall under a bespoke definition…
CTA09/S604A These guidelines apply to accounting periods of the company beginning on or after January…
CTA09/PT5/CH8 Overview Under normal lending relationship rules, interest is exempt when accrued in accounts, not…
TIOPA10/S423 The default approach for the calculation of group interest and group EBITDA is closely…
CTA09/S465B and S702 When a company holds a loan or derivative whose amounts are recognized…
Investor taxation The main cash flows of a securitization are the claims on the securitized…
These guidelines apply to accounting periods of the company beginning on or after January 1,…
What does the Corporate Finance Manual contain? The Corporate Finance Handbook begins with an explanation…
Insight Many entries in a company’s corporation tax return, in particular its trading profit, will…
TIOPA10/S461 The Corporate Interest Restriction contains an Anti-Avoidance Plan Rule (RAAR) which has the effect…
The corporate tax charge: the formula: ‘RP’ and ‘DS’ Regulation 14(1) establishes the basis on…
TIOPA10/445 The basic election of QIC joint venture under TIOPA10/S444 applies when the joint venture…
TIOPA10/S388 Where income is derived from a foreign jurisdiction for a UK resident company and…
Main features of pension company taxation rules Schedule 13 of the FA 2007 introduced major…
CTA09/S607ZA Relief for pre-opening financing charges From 6 April 2020, a non-resident company which carries…
Processing of warranty contracts The lender of the securities will normally require security from the…
SI 2004/3271: 3C regulation Certain debits and credits resulting from a change in accounting method…
S316 (lending relationships) and S614 (derivative contracts) are the main provisions for taking into account…
TIOPA/S406(5)-(7) The purpose of the calculations is to arrive at an overall tax-EBITDA figure for…
Many holders and issuers of convertible or exchangeable securities, or asset-linked securities, will separately account…
F(2)A15/SCH7/PARAS120-129 The changes made to the provisions relating to derivative contracts by F(2)A15 affected not…
The calculation of the group’s net interest expense (MIGN) is based on the amounts recognized…
These guidelines apply to worldwide group accounting periods ending on or before April 1, 2017.…
The legislative remedy: relevant effects 1 and 2 The first relevant effect, in Section 759(3),…
TIOPA10/S440-S442 Although a company is a qualifying infrastructure company (QIC), in addition to exempting certain…
CTA09/S352B Tax asymmetries can arise in situations where a company borrows externally and then lends…
Example of an avoidance scheme to alleviate interest and principal Example 1: ‘plain vanilla’ loan…
TIOPA 2010/S452 The Corporate Interest Restriction (CIR) applies to Real Estate Investment Trusts (REITs) and…
CTA10/S14, 15 Loss carry forward CTA10/S14 deals with the situation where a company, in accordance…
SANTA CLARA, Calif .– (COMMERCIAL THREAD) – Intel Corporation today announced that its board of…