SCHEDULES

SCHEDULE 15U.K.Tax treatment of financing costs and income

Modifications etc. (not altering text)

C1Sch. 15 modified (21.7.2009 retrospective) by Finance (No. 3) Act 2010 (c. 33), Sch. 5 para. 36(2)

Part 1U.K.Introduction

OverviewU.K.

1(1)Part 2 contains provision for determining whether this Schedule applies in relation to any particular period of account of the worldwide group.U.K.

(2)Part 3 provides for the disallowance of certain financing expenses of relevant group companies arising in a period of account of the worldwide group to which this Schedule applies.

The total of the amounts disallowed is the amount by which the tested expense amount (defined in Part 8) exceeds the available amount (defined in Part 9).

(3)Part 4 provides for the exemption from the charge to corporation tax of certain financing income of UK group companies where financing expenses of relevant group companies have been disallowed under Part 3.

(4)Part 5 provides for the exemption from the charge to corporation tax of certain intra-group financing income of UK group companies where the paying company is denied a deduction for tax purposes otherwise than under this Schedule.

(5)Part 6 contains rules connected with tax avoidance.

(6)Part 7 defines “financing expense amounts” and “financing income amounts” of a company for a period of account of the worldwide group, which are amounts that would, apart from this Schedule, be brought into account for the purposes of corporation tax.

(7)Part 8 defines the “tested expense amount” and the “tested income amount” of the worldwide group for a period of account of the group, which are totals deriving from the financing expense amounts and financing income amounts of certain group companies.

(8)Part 9 defines the “available amount” for a period of account of the worldwide group, which derives from certain financing costs disclosed in the group's consolidated financial statements.

(9)Part 10 contains further interpretative provisions.

(10)Part 11 contains consequential provision and provision about commencement.