Schedules

Schedule 3U.K.Corporate interest restriction etc.

Part 1U.K.Amendments to TIOPA 2010

Capitalised interest brought into account for tax purposes in accordance with GAAPU.K.

12(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)”.