INTM217100 - Controlled Foreign Companies: The CFC charge gateway chapter 9 - exemptions for profits from qualifying loan relationships: what is a qualifying loan relationship: the ultimate debtor rule - detailed application: contents

The 바카라 사이트渦ltimate debtor바카라 사이트� condition ensures that a qualifying loan relationship is defined by reference to who, in substance, the real borrower is. TIOPA10/Part 9A/S371IG(2) provides that the ultimate debtor is the immediate debtor in relation to a qualifying loan relationship (바카라 사이트淨LR바카라 사이트� - INTM217000) unless section 371IG(3) applies to look through any conduit type arrangements

  1. INTM217110
    Loans made to fund another loan
  2. INTM217120
    Arrangements involving equity investments
  3. INTM217130
    Loans made to acquire an existing loan
  4. INTM217140
    Loans used for more than one purpose
  5. INTM217150
    Test by reference to each accounting period
  6. INTM217160
    Loans to Partnerships and other transparent entities
  7. INTM217170
    Loans to Banking, Insurance and Group Treasury Companies
  8. INTM217180
    Interaction of amounts exempted under Chapter 9 and subsequent adjustments under Chapter 6
  9. INTM217190
    Cash Pooling