CFM73160 – Corporate Finance Manual – HMRC Internal Manual
Deduction for financial expenses The objective of the structured finance rules is to ensure the…
CFM33160 – Corporate Finance Manual – HMRC Internal Manual
CTA09/S320 Capitalized amounts These guidelines cover cases where interest is capitalized in a company’s financial…
CFM76040 – Corporate Finance Manual – HMRC Internal Manual
CTA09/S465B and S702 In the event of a change in the basis of accounting for…
CFM98580 – Corporate Finance Manual – HMRC Internal Manual
TIOPA10/SCH7A/PARA22 Where a reporting company concludes that the total disallowed amount (TIOPA10/S373(2) for the global…
CFM72620 – Corporate Finance Manual – HMRC Internal Manual
Commencement and termination as a securitization company A new company created from January 1, 2007…
CFM72680 – Corporate Finance Manual – HMRC Internal Manual
Other tax rules Transfer price See INTM566010 for guidance on thin capitalization issues in securitization…
CFM98693 – Corporate Finance Manual – HMRC Internal Manual
CTA10/S679 TIOPA10/S379 CTA10/PT14, “Change in Business Ownership” contains detailed rules that may restrict relief for…
CFM90150 – Corporate Finance Manual – HMRC Internal Manual
These guidelines apply to worldwide group accounting periods ending on or before April 1, 2017.…
CFM99300 – Corporate Finance Manual – HMRC Internal Manual
Priority rules The CIR applies after most other tax rules that may affect the calculation…
CFM55210 – Corporate Finance Manual – HMRC Internal Manual
Aspects of taxable gains from convertible and exchangeable securities – the holder’s perspective Securities that…
CFM98360 – Corporate Finance Manual – HMRC Internal Manual
F(No.2)A17/Sch5/Para29-30 The business interest restriction applies to tax-interest and tax-EBITDA amounts. These in turn are…
CFM35985 – Corporate Finance Manual – HMRC Internal Manual
FA15/S25 What changes have been made? FA15/S25 limited the categories of connection to which the…
CFM55510 – Corporate Finance Manual – HMRC Internal Manual
CTA09/S665, 666 References to a standard convertible are instruments where the holder has the option…
CFM95720 – Corporate Finance Manual – HMRC Internal Manual
TIOPA10/S406, S407 Adjusted corporation tax revenue is a company’s taxable profit or loss for an…
CFM37850 – Corporate Finance Manual – HMRC Internal Manual
Where an instrument meets the CTA09/S475C definition of a hybrid capital instrument, the tax rules…
CFM72590 – Corporate Finance Manual – HMRC Internal Manual
The corporate tax charge: the formula: ‘D’ D is the lesser of: the sum of…
CFM97745 – Corporate Finance Manual – HMRC Internal Manual
TIOPA10/S452(6) to (10) Example 1 A UK REIT group has a refusal of CIR of…
CFM72260 – Corporate Finance Manual – HMRC Internal Manual
Securitization Companies (Application of Article 83(1) of the Finance Act 2005: Accounting Standards) Regulations 2007…
CFM70020 – Corporate Finance Manual – HMRC Internal Manual
CFM70010 explains that certain tax rules relating to corporate debt are found outside the main…
CFM60010 – Corporate Finance Manual – HMRC Internal Manual
Exchange gains and losses This part of the Corporate Finance Manual deals with the taxation…
CFM37830 – Corporate Finance Manual – HMRC Internal Manual
The hybrid capital instrument rules apply to loan relationships that fall under a bespoke definition…
CFM51036 – Corporate Finance Manual – HMRC Internal Manual
CTA09/S604A These guidelines apply to accounting periods of the company beginning on or after January…
CFM35810 – Corporate Finance Manual – HMRC Internal Manual
CTA09/PT5/CH8 Overview Under normal lending relationship rules, interest is exempt when accrued in accounts, not…
CFM96640 – Corporate Finance Manual – HMRC Internal Manual
TIOPA10/S423 The default approach for the calculation of group interest and group EBITDA is closely…
CFM76048 – Corporate Finance Manual – HMRC Internal Manual
CTA09/S465B and S702 When a company holds a loan or derivative whose amounts are recognized…
CFM72700 – Corporate Finance Manual – HMRC Internal Manual
Investor taxation The main cash flows of a securitization are the claims on the securitized…
CFM52033 – Corporate Finance Handbook – HMRC Internal Handbook
These guidelines apply to accounting periods of the company beginning on or after January 1,…
CFM1120 – Corporate Finance Manual – HMRC Internal Manual
What does the Corporate Finance Manual contain? The Corporate Finance Handbook begins with an explanation…
CFM64010 – Corporate Finance Manual – HMRC Internal Manual
Insight Many entries in a company’s corporation tax return, in particular its trading profit, will…
CFM98010 – Corporate Finance Manual – HMRC Internal Manual
TIOPA10/S461 The Corporate Interest Restriction contains an Anti-Avoidance Plan Rule (RAAR) which has the effect…
CFM72580 – Corporate Finance Manual – HMRC Internal Manual
The corporate tax charge: the formula: ‘RP’ and ‘DS’ Regulation 14(1) establishes the basis on…
CFM96950 – Corporate Finance Manual – HMRC Internal Manual
TIOPA10/445 The basic election of QIC joint venture under TIOPA10/S444 applies when the joint venture…
CFM95680 – Corporate Finance Manual – HMRC Internal Manual
TIOPA10/S388 Where income is derived from a foreign jurisdiction for a UK resident company and…
CFM46200 – Corporate Finance Manual – HMRC Internal Manual
Main features of pension company taxation rules Schedule 13 of the FA 2007 introduced major…
CFM51095 – Corporate Finance Manual – HMRC Internal Manual
CTA09/S607ZA Relief for pre-opening financing charges From 6 April 2020, a non-resident company which carries…
CFM74120 – Corporate Finance Manual – HMRC Internal Manual
Processing of warranty contracts The lender of the securities will normally require security from the…
CFM76100 – Corporate Finance Manual – HMRC Internal Manual
SI 2004/3271: 3C regulation Certain debits and credits resulting from a change in accounting method…
CFM76020 – Corporate Finance Manual – HMRC Internal Manual
S316 (lending relationships) and S614 (derivative contracts) are the main provisions for taking into account…
CFM95730 – Corporate Finance Manual – HMRC Internal Manual
TIOPA/S406(5)-(7) The purpose of the calculations is to arrive at an overall tax-EBITDA figure for…
CFM37780 – Corporate Finance Manual – HMRC Internal Manual
Many holders and issuers of convertible or exchangeable securities, or asset-linked securities, will separately account…
CFM52038 – Corporate Finance Manual – HMRC Internal Manual
F(2)A15/SCH7/PARAS120-129 The changes made to the provisions relating to derivative contracts by F(2)A15 affected not…
CFM95990 – Corporate Finance Manual – HMRC Internal Manual
The calculation of the group’s net interest expense (MIGN) is based on the amounts recognized…
CFM92457 – Corporate Finance Manual – HMRC Internal Manual
These guidelines apply to worldwide group accounting periods ending on or before April 1, 2017.…
CFM73100 – Corporate Finance Manual – HMRC Internal Manual
The legislative remedy: relevant effects 1 and 2 The first relevant effect, in Section 759(3),…
CFM97380 – Corporate Finance Manual – HMRC Internal Manual
TIOPA10/S440-S442 Although a company is a qualifying infrastructure company (QIC), in addition to exempting certain…
CFM35175 – Corporate Finance Manual – HMRC Internal Manual
CTA09/S352B Tax asymmetries can arise in situations where a company borrows externally and then lends…
CFM73030 – Corporate Finance Manual – HMRC Internal Manual
Example of an avoidance scheme to alleviate interest and principal Example 1: ‘plain vanilla’ loan…
CFM97710 – Corporate Finance Manual – HMRC Internal Manual
TIOPA 2010/S452 The Corporate Interest Restriction (CIR) applies to Real Estate Investment Trusts (REITs) and…
CFM64445 – Corporate Finance Manual – HMRC Internal Manual
CTA10/S14, 15 Loss carry forward CTA10/S14 deals with the situation where a company, in accordance…
Intel promotes two corporate executives, elects six new corporate vice presidents
SANTA CLARA, Calif .– (COMMERCIAL THREAD) – Intel Corporation today announced that its board of…