Taxation (International and Other Provisions) Act 2010 section 371II

Power to amend definitions

Section 371II gives HMRC the power to change, by regulations, certain key definitions used in the rules on exemptions for profits from qualifying loan relationships of controlled foreign companies (CFCs).

• HMRC Commissioners may make regulations to amend the CFC qualifying loan relationships chapter of the legislation.
• The definition of "qualifying resources" (used to determine whether loans are funded from appropriate sources) can be amended by regulation.
• The definitions of "qualifying loan relationship" and "ultimate debtor" can also be amended by regulation.
• This regulation-making power allows HMRC to update these definitions without requiring a new Act of Parliament.