Schedules

Schedule 3Corporate interest restriction etc.

Part 1Amendments to TIOPA 2010

12Capitalised interest brought into account for tax purposes in accordance with GAAP

1

Section 423 (capitalised interest brought into account for tax purposes in accordance with GAAP) is amended as follows.

2

After subsection (2A) insert—

2AA

Section 413 has effect, in the case of a GAAP-taxable asset within subsection (2AB), as if—

a

the definition of “upward adjustment” included so much of its carrying value as is attributable to a relevant expense amount (whether or not that amount is brought into account in the group’s financial statements for the relevant period of account); and

b

the definition of “downward adjustment” included so much of its carrying value as is attributable to a relevant income amount (whether or not that amount is brought into account in the group’s financial statements for the relevant period of account).

2AB

A GAAP-taxable asset is within this subsection if it is (or, under section 173 of TCGA 1992, is treated as being) appropriated, in a relevant accounting period in relation to a period of account, from trading stock to fixed assets.

3

In subsection (3), for “(2)(b) and (2A)” substitute “(2)(b), (2A) and (2AA)”.