The Corporate Interest Restriction (Consequential Amendments) Regulations 2017

Amendments to the Authorised Investment Funds (Tax) Regulations 2006

2.—(1) The Authorised Investment Funds (Tax) Regulations 2006(1) are amended as follows.

(2) In regulation 18 (interest distributions: general), after paragraph (2) insert—

“(2A) For the purposes of Part 10 (Corporate Interest Restriction) of TIOPA 2010, an interest distribution is treated as not being a tax-interest expense amount(2) of the authorised investment fund.”

(3) In regulation 69Z16 (PAIF distributions (interest))(3), after paragraph (2) insert—

“(2A) For the purposes of Part 10 (Corporate Interest Restriction) of TIOPA 2010, a PAIF distribution (interest) is treated as not being a tax-interest expense amount of the company.”

(4) In regulation 69Z61 (TEF distributions (non-dividend))(4), after paragraph (2) insert—

“(2A) For the purposes of Part 10 (Corporate Interest Restriction) of TIOPA 2010, a TEF distribution (non-dividend) is treated as not being a tax-interest expense amount of the Tax Elected Fund.”

(1)

S.I. 2006/964; relevant amending instruments are S.I. 2008/705 and 2009/2036.

(2)

A new Part 10 was inserted into the Taxation (International and Other Provisions) Act 2010 (c. 8) by paragraph 1 of Schedule 5 to the Finance (No. 2) Act 2017; “tax-interest expense amount” is defined in section 382 of that Part.

(3)

Regulation 69Z16 was inserted by S.I. 2008/705.

(4)

Regulation 69Z61 was inserted by S.I. 2009/2036.