CFM90860 - Debt cap: financial services groups: the meaning of 바카라 사이트˜substantially all바카라 사이트™
This guidance applies to worldwide group periods of account ending before or straddling 1 April 2017.
TIOPA10/S266 (2) requires that 바카라 사이트˜substantially all바카라 사이트™ of the trading income must be derived from qualifying activities
It would be very unusual for a financial services group to have 100% of its trading income derived from qualifying activities; groups have diverse business operations and a condition based on 100% qualifying activity would have little practical impact. However, a balance is needed as the financial exclusion should only apply to groups whose business activities require debt as part of their operating models.
TIOPA10/S266 (2) refers to substantially all the trading income (either the worldwide trading income or UK trading income) being derived from qualifying activities. The expression 바카라 사이트˜substantially all바카라 사이트™ is not defined in legislation. In practice HMRC will interpret the expression as meaning around 90%. A degree of flexibility can be applied; for example if a group consistently has more than 90% of its trading income being derived from qualifying activities, but finds in one year it is just below 90% then the group would be treated as meeting the 바카라 사이트˜substantially all바카라 사이트™ test.