Taxation (International and Other Provisions) Act 2010

[F1 374 Interest restriction returns U.K.

(1) Schedule 7A makes provision about—

(a) the preparation and submission of interest restriction returns by reporting companies of worldwide groups, and

(b) other related matters such as enquiries and information powers.

(2) Part 1 of that Schedule includes provision—

(a) for the appointment of a reporting company of a worldwide group for a period of account, but

(b) for companies (“non-consenting companies”) to elect to be unaffected by allocations of interest restrictions made by the company.

(3) Part 2 of that Schedule includes provision—

(a) for various elections to be made in an interest restriction return that are relevant to the operation of this Part (for example, the group ratio election),

(b) entitling the reporting company of a worldwide group to allocate interest restrictions among its members but with a rule that allocates a pro-rata share to a non-consenting company, and

(c) entitling the reporting company of a worldwide group to allocate interest reactivations among its members.

(4) The remaining Parts of that Schedule contain provision about—

(a) the keeping and preservation of records (see Part 3),

(b) enquiries into interest restriction returns (see Part 4),

(c) determinations made by officers of Revenue and Customs in the event of the breach of filing or other obligations (see Part 5),

(d) information powers exercisable by members of the group (see Part 6),

(e) information powers exercisable by officers of Revenue and Customs (see Part 7), and

(f) the amendment of company tax returns to reflect the effect of this Part of this Act and supplementary matters (see Parts 8 and 9).]

Textual Amendments

F1 Pt. 10: the existing Pt. 10 renumbered as Pt. 11 (except for ss. 375, 376 which are repealed), the existing ss. 372-374, 377-382 renumbered as ss. 499-507 and a new Pt. 10 (ss. 372-498) inserted (with effect in accordance with Sch. 5 para. 25(1)-(3) of the amending Act) by Finance (No. 2) Act 2017 (c. 32), Sch. 5 para. 1, 10(1)(2)(a)(3) (with Sch. 5 paras. 27, 32-34)