[INTM203510] INTM203510 – Controlled Foreign Companies: The CFC Charge Gateway Chapter 5 – Non-trading finance profits: Capital investment from the UK: Relevant UK funds or other assets
Any non-trading finance profits arising from the investment of ‘relevant UK funds or other assets’ as defined by TIOPA10/S371EC(4) fall within Chapter 5. For these purposes ‘UK funds’ are monetary assets and ‘other assets’ are non-monetary assets. Regardless of where the Significant People Functions (SPFs) are, there will still be Chapter 5 profits if the CFC has earned non-trading finance profits from loans that are funded from relevant UK funds.
‘Relevant UK funds or other assets’ are defined at TIOPA10/S371EC(4) as funds or assets which represent or are derived directly, or indirectly, from the following sources.