Chapter CFM91230

Published date16 April 2016
Record NumberCFM91230
CourtHM Revenue & Customs
IssuerHM Revenue & Customs
This guidance applies to worldwide group periods of account ending before or straddling 1 April 2017.
Establishing the financing income amounts

The net financing income is the sum of the relevant group company’s financing income amounts for the period less the sum of the company’s financing expense amounts for the period. Financing income amounts are defined in TIOPA10/S314 in a precisely similar way to the definition of financing expense amounts in section 313. As with financing expense amounts, there are specific exclusions in sections 316 to 327 - further detail can be found at CFM92000+.

The financing income amounts of a company for a period of account of the worldwide group is any amount that meets three conditions in TIOPA10/S314. An amount is financing income if, apart from the operation of Part 7 it would be brought into account:

  • as a trading or non-trading credit, in respect of a loan relationship (but see below for exceptions); or
  • for the purposes of corporation tax as financing income implicit in payments received under finance leases; or
  • for the...

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