Taxation (International and Other Provisions) Act 2010

[F1 A company's pro-rata share of the total disallowed amount U.K.

Textual Amendments

F1 Sch. 7A inserted (with effect in accordance with Sch. 5 para. 25(1)(2) of the amending Act) by Finance (No. 2) Act 2017 (c. 32), Sch. 5 para. 2 (with Sch. 5 para. 28)

23 (1) This paragraph— U.K.

(a) applies in relation to a worldwide group that is subject to interest restrictions in a period of account of the group, and

(b) allocates the total disallowed amount of the group in the period to companies that are UK group companies at any time during the period.

(2) The amount allocated to a company under this paragraph is referred to in this Part of this Act as the company's “pro-rata share” of the total disallowed amount.

(3) Sub-paragraph (4) applies in relation to a company that has net tax-interest expense for the period of account.

(4) The amount of the total disallowed amount that is allocated to the company is—

where—

A is the total disallowed amount;

B is the net tax-interest expense of the company for the period of account;

C is the sum of the net tax-interest expense for the period of account of each company that has net tax-interest expense for the period.

(5) Where this paragraph does not allocate any of the total disallowed amount to a company, the company's “pro-rata share” of the total disallowed amount is nil.]