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Taxation (International and Other Provisions) Act 2010
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Section 379
SCHEDULE 11U.K.Index of defined expressions used in Parts 2 to 8
This schedule has no associated Explanatory Notes
Part 1U.K.Double taxation relief: index of defined expressions used in Parts 2 and 3
| the arrangements (in Chapter 2 of Part 2) | section 21(1) |
| chargeable gain (in Part 2 so far as relating to capital gains tax) | section 105 |
| double taxation arrangements (in Part 2) | section 2(4) |
| double taxation arrangements (in Part 3) | section 136(2) |
| foreign tax (in Chapter 2 of Part 2) | section 21(1) |
| [F1insurance company | section 65 of FA 2012 (as applied by section 141(2) of that Act)] |
| international arrangements (in Part 3) | section 136(3) |
| [F1long-term business | section 63 of FA 2012 (as applied by section 141(2) of that Act)] |
| the non-UK territory (in Chapter 2 of Part 2) | section 21(1) |
| the Savings Directive (in Part 3) | section 136(4) |
| savings income (in Part 3) | section 136(5) |
| special withholding tax (in Part 3) | section 136(6) |
| tax not chargeable directly or by deduction (in Chapter 2 of Part 2) | sections 17(3) and 20(4) |
| tax payable or chargeable (in Chapter 2 of Part 2) | sections 17(3) and 20(4) |
| tax payable or paid under the law of a territory outside the United Kingdom (in Chapter 2 of Part 2, except section 29, in its application to relief under unilateral relief arrangements) | section 8(2) |
| underlying tax (in Chapter 2 of Part 2) | section 21(1) |
| unilateral relief arrangements (in Part 2) | section 8(1) |
Textual Amendments
F1Words in Sch. 11 Pt. 1 inserted (17.7.2012) by Finance Act 2012 (c. 14), Sch. 16 para. 244
Part 2U.K.Transfer pricing: index of defined expressions used in Part 4
| the actual provision (in Part 4) | section 149 |
| the advantaged person (in Chapter 4 of Part 4) | section 174(1) |
| the affected persons (in Part 4) | section 149(1), (2) |
| the arm's length provision (in Part 4) | section 151 |
| control (of a body corporate or firm) (in Part 4) | section 217 |
| the disadvantaged person (in Chapter 4 of Part 4) | section 174(1) |
| firm (in Part 4) | section 217(8) |
| the guarantor company (in Chapter 5 of Part 4) | section 191(5) |
| the issuing company (in Chapter 5 of Part 4) | section 191(5) |
| losses (in Part 4) | section 156(1) |
| medium-sized enterprise (in Chapter 3 of Part 4) | section 172 |
| participation (direct or indirect) in the management, control or capital of another person (in Part 4) | Chapter 2 of Part 4 |
| potential advantage in relation to United Kingdom taxation (in Part 4) | section 155(2) |
| profits (in Part 4) | section 156(2) |
| the relevant activities (in Part 4) | section 216 |
| relevant notice (in Chapter 4 of Part 4) | section 190 |
| section 182 claim (in Part 4) | section 181(3) |
| the security (in Chapter 5 of Part 4) | section 191(5) |
| small enterprise (in Chapter 3 of Part 4) | section 172 |
| transaction, and series of transactions (in Part 4) | section 150 |
| transfer pricing notice (in Chapter 3 of Part 4) | section 168(2) |
Part 3U.K.Advance pricing agreements: index of defined expressions used in Part 5
| advance pricing agreement (in Part 5) | section 218(1) |
| the Commissioners (in Part 5) | section 230 |
| officer (in Part 5) | section 230 |
F2Part 4U.K.Tax arbitrage: index of defined expressions used in Part 6
Textual Amendments
F2Sch. 11 Pt. 4 omitted (with effect in accordance with Sch. 10 para. 22 of the amending Act) by virtue of Finance Act 2016 (c. 24), Sch. 10 para. 16
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
[F3PART 4AU.K.Hybrid and other mismatches: index of defined expressions used in Part 6A
Textual Amendments
F3Sch. 11 Pt. 4A inserted (15.9.2016) by Finance Act 2016 (c. 24), Sch. 10 para. 17
| arrangement (in Part 6A) | section 259NF |
| CFC and CFC charge (in Part 6A) | section 259B(4) |
| the Commissioners (in Part 6A) | section 259NF |
| control group (in Part 6A) | section 259NB |
| deduction period (in Chapter 10 of Part 6A) | section 259JA(5)(a) |
| dual resident company (in Chapter 10 of Part 6A) | section 259JA(3) |
| dual territory double deduction amount (in Chapter 10 of Part 6A) | section 259JA(5) |
| dual territory double deduction (in Chapter 11 of Part 6A) | section 259KB |
| excessive PE deduction (in Chapter 6 of Part 6A) | section 259FA(8) |
| excessive PE deduction (in Chapter 11 of Part 6A) | section 259KB |
| financial instrument (in Part 6A) | section 259N |
| foreign CFC and foreign CFC charge (in Part 6A) | section 259B(4) |
| foreign deduction period (in Chapter 10 of Part 6A) | section 259JA(5)(b) |
| hybrid entity (in Part 6A) | section 259BE |
| hybrid entity deduction period (in Chapter 9 of Part 6A) | section 259IA(2)(a) |
| hybrid entity double deduction amount (in Chapter 9 of Part 6A) | section 259IA(4) |
| hybrid or otherwise impermissible deduction/non-inclusion mismatch (in Chapter 3 of Part 6A) | section 259CB |
| hybrid payee (in Chapter 7 of Part 6A) | section 259GA(3) |
| hybrid payee deduction/non-inclusion mismatch (in Chapter 7 of Part 6A) | section 259GB |
| hybrid payer (in Chapter 5 of Part 6A) | section 259EA(3) |
| hybrid payer deduction/non-inclusion mismatch (in Chapter 5 of Part 6A) | section 259EB |
| hybrid transfer arrangement (in Chapter 4 of Part 6A) | section 259DB |
| hybrid transfer deduction/non-inclusion mismatch (in Chapter 4 of Part 6A) | section 259DC |
| imported mismatch payment (in Chapter 11 of Part 6A) | section 259KA(2) |
| imported mismatch arrangement (in Chapter 11 of Part 6A) | section 259KA(2) |
| investor (in Part 6A) | section 259BE(4) |
| investor deduction period (in Chapter 9 of Part 6A) | section 259IA(2)(b) |
| investor jurisdiction (in Part 6A) | section 259BE(4) |
| mismatch payment (in Chapter 11 of Part 6A) | section 259KA(6) |
| multinational company (in Chapter 6 of Part 6A) | section 259FA(3) |
| multinational company (in Chapter 8 of Part 6A) | section 259HA(4) |
| multinational payee deduction/non-inclusion mismatch (in Chapter 8 of Part 6A) | section 259HB |
| ordinary income (in Part 6A) | sections 259BC and 259BD |
| over-arching arrangement (in Chapter 11 of Part 6A) | section 259KA(5) |
| P (in Chapter 11 of Part 6A) | section 259KA(3) |
| parent jurisdiction (in Chapter 6 of Part 6A) | section 259FA(3)(a) |
| parent jurisdiction (in Chapter 8 of Part 6A) | section 259HA(4)(a) |
| parent jurisdiction (in Chapter 10 of Part 6A) | section 259JA(4)(b)(ii) |
| payee (in Part 6A) | section 259BB(6) |
| payee jurisdiction (in Part 6A) | section 259BB(9) |
| payer (in Part 6A) | section 259BB(1)(a) or (2) |
| payment (in Part 6A) | section 259BB(1) |
| payment period (in Part 6A) | section 259BB(1)(b) or (2) |
| PE jurisdiction (in Chapter 8 of Part 6A) | section 259HA(4)(b) |
| PE jurisdiction (in Chapter 10 of Part 6A) | section 259JA(4)(a) |
| PE jurisdiction (in Chapter 11 of Part 6A) | section 259KB(3)(a) |
| permanent establishment (in Part 6A) | section 259BF |
| quasi-payment (in Part 6A) | section 259BB(2) to (5) |
| related (in Part 6A) | section 259NC |
| relevant deduction (in Part 6A) | section 259BB(1)(b) or (2)(a) |
| relevant investment fund (in Part 6A) | section 259NA |
| relevant mismatch (in Chapter 11 of Part 6A) | section 259KA(6) |
| relevant multinational company (in Chapter 10 of Part 6A) | section 259JA(4) |
| relevant PE period (in Chapter 6 of Part 6A) | section 259FA(4) |
| series of arrangements (in Chapter 11 of Part 6A) | section 259KA(5) |
| substitute payment (in Chapter 4 of Part 6A) | section 259DB(5) |
| tax (in Part 6A) | section 259B |
| taxable period (in Part 6A) | section 259NF |
| taxable profits (in Part 6A) | sections 259BC(2) and 259BD(5) |
| underlying instrument (in Chapter 4 of Part 6A) | section 259DB(3) |
| underlying return (in Chapter 4 of Part 6A) | section 259DB(5)(b)] |
F4Part 5U.K.Tax treatment of financing costs and income: index of defined expressions used in Part 7
Textual Amendments
F4Sch. 11 Pt. 5 repealed (with effect in accordance with Sch. 5 para. 26(1) of the amending Act) by Finance (No. 2) Act 2017 (c. 32), Sch. 5 para. 11(1)(c)
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Part 6U.K.Offshore funds: index of defined expressions used in Part 8
| participant (in Part 8) | section 362(1) |
| participation (in Part 8) | section 362(2) |
| part of umbrella arrangements (in Part 8) | section 363(2) |
| umbrella arrangements (in Part 8) | section 363(1) |
[F5PART 7U.K.Corporate interest restriction: index of defined expressions used in Part 10
Textual Amendments
F5Sch. 11 Pt. 7 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. 24
| abbreviated interest restriction return (in Part 10) | paragraph 20 of Schedule 7A |
| abbreviated return election (in Part 10) | paragraph 19 of Schedule 7A |
| accounting period (in Part 10) | Chapter 2 of Part 2 of CTA 2009 (applied by section 1119 of CTA 2010) |
| adjusted net group-interest expense of a worldwide group (in Part 10) | section 413 |
| aggregate net tax-interest expense of a worldwide group (in Part 10) | section 390 |
| aggregate net tax-interest income of a worldwide group (in Part 10) | section 390 |
| aggregate tax-EBITDA of a worldwide group (in Part 10) | section 405 |
| allocated reactivation of company for period of account (in Part 10) | paragraph 25 of Schedule 7A |
| allowable loss (in Part 10) | TCGA 1992 (applied by section 1119 of CTA 2010) |
| associated (in Chapter 8 of Part 10) | section 449(2) |
| amount available for reactivation of company in period of account (in Part 10) | paragraph 26 of Schedule 7A |
| available, in relation to interest allowance (in Chapter 4 of Part 10) | section 393 |
| balance sheet (in Chapter 8 of Part 10) | section 449(1) |
| chargeable gain (in Part 10) | TCGA 1992 (applied by section 1119 of CTA 2010) |
| the Commissioners (in Part 10) | section 494(1) |
| company (in Part 10) | section 1121 of CTA 2010 |
| company tax return (in Schedule 7A) | paragraph 73 of Schedule 7A |
| consenting company (in Part 10) | paragraph 10 of Schedule 7A |
| consolidated partnership (in Part 10) | section 430 |
| consolidated subsidiary of another entity (in Part 10) | section 475 |
| derivative contract (in Part 10) | Part 7 of CTA 2009 (applied by section 1119 of CTA 2010) |
| disallowed, in relation to tax-interest expense amount (in Part 10) | section 378 |
| drawn up on acceptable principles, in relation to financial statements (in Chapter 11 of Part 10) | section 481 |
| fair value accounting (in Part 10) | section 494(1) |
| fair value (in Part 10) | section 494(1) |
| filing date, in relation to a period of account of a worldwide group (in Part 10) | paragraph 7(5) of Schedule 7A |
| finance lease (in Part 10) | section 494(1) |
| financial asset (in Chapter 8 of Part 10) | section 449(1) |
| financial statements of a worldwide group (in Part 10) | section 479 |
| fixed ratio method (in Part 10) | section 397 |
| for accounting purposes (in Part 10) | section 1127(4) of CTA 2010 |
| full interest restriction return (in Part 10) | paragraph 20 of Schedule 7A |
| generally accepted accounting practice (in Part 10) | section 1127(1) and (3) of CTA 2010 |
| group-EBITDA (chargeable gains) election (in Part 10) | paragraph 15 of Schedule 7A |
| group ratio election (in Part 10) | paragraph 13 of Schedule 7A |
| group ratio (blended) election (in Part 10) | paragraph 14 of Schedule 7A |
| group ratio method (in Part 10) | section 398 |
| group ratio percentage (in Part 10) | section 399 |
| IAS financial statements (in Part 10) | section 488 |
| impairment loss (in Part 10) | section 391 |
| income (in Part 10) | section 1119 of CTA 2010 |
| insurance company (in Part 10) | section 141 of FA 2012 |
| interest allowance of a worldwide group (in Part 10) | section 396 |
| interest allowance (alternative calculation) election (in Part 10) | paragraph 16 of Schedule 7A |
| interest allowance (consolidated partnerships) election (in Part 10) | paragraph 18 of Schedule 7A |
| interest allowance (non-consolidated investment) election (in Part 10) | paragraph 17 of Schedule 7A |
| interest capacity of a worldwide group (in Part 10) | section 392 |
| interest reactivation cap of a worldwide group (in Part 10) | section 373 |
| interest restriction return (in Part 10) | section 494(1) |
| international accounting standards (in Part 10) | section 1127(5) of CTA 2010 |
| investor in a worldwide group (in Part 10) | section 404 |
| loan relationship (in Part 10) | Part 5 of CTA 2009 (applied by section 1119 of CTA 2010) |
| loan relationships or other financing arrangements (in Chapter 8 of Part 10) | section 449(1) |
| local authority (in Part 10) | section 1130 of CTA 2010 |
| local authority association (in Part 10) | section 1131 of CTA 2010 |
| member of a worldwide group (in Part 10) | section 473(4)(a) |
| multi-company worldwide group (in Part 10) | section 473(4)(d) |
| net group-interest expense of a worldwide group (in Part 10) | section 410 |
| net tax-interest expense of a company (in Part 10) | section 389 |
| net tax-interest income of a company (in Part 10) | section 389 |
| non-consenting company (in Part 10) | paragraph 10 of Schedule 7A |
| non-consolidated associate of a worldwide group (in Part 10) | section 429 |
| non-consolidated subsidiary of an entity (in Part 10) | section 475 |
| notice (in Part 10) | section 1119 of CTA 2010 |
| party to a loan relationship (in Part 10) | section 494(2) |
| [F6pension scheme (in Part 10) | section 494(1)] |
| period of account of a worldwide group (in Part 10) | section 480 |
| profit before tax, of a worldwide group (in Chapter 7 of Part 10) | section 416 |
| pro-rata share of company (of total disallowed amount) (in Part 10) | paragraph 23 of Schedule 7A |
| pro-rata share of accounting period (of total disallowed amount) (in Part 10) | paragraph 24 of Schedule 7A |
| provision (in relation to a public infrastructure asset) (in Chapter 8 of Part 10) | section 436 |
| public infrastructure asset (in Chapter 8 of Part 10) | section 436 |
| qualifying charitable donation (in Part 10) | Part 6 of CTA 2010 (applied by section 1119 of CTA 2010) |
| qualifying infrastructure company (in Chapter 8 of Part 10) | section 433 |
| qualifying infrastructure activity (in Chapter 8 of Part 10) | section 436 |
| qualifying net group-interest expense of a worldwide group (in Part 10) | section 414 |
| recognised, in financial statements (in Part 10) | section 489 |
| recognised stock exchange (in Part 10) | section 1137 of CTA 2010 |
| registered pension scheme (in Part 10) | section 150(2) of FA 2004 (applied by section 1119 of CTA 2010) |
| related party (in Part 10) | sections 462 to 472 |
| related party investor (in Part 10) | section 404 |
| relevant asset (in Chapter 7 of Part 10) | section 417 |
| relevant accounting period (in Part 10) | section 490 |
| relevant expense amount (in Chapter 7 of Part 10) | section 411 |
| relevant income amount (in Chapter 7 of Part 10) | section 411 |
| relevant public body (in Part 10) | section 491 |
| reporting company (in Part 10) | section 494(1) |
| the return period (in Part 10) | section 494(1) |
| service concession agreement (in Part 10) | section 494(1) |
| share, of an investor in a worldwide group (in Part 10) | section 404 |
| single-company worldwide group (in Part 10) | section 473(4)(c) |
| subject to interest reactivations (in Part 10) | section 373 |
| subject to interest restrictions (in Part 10) | section 373 |
| tax (in Part 10) | section 1119 of CTA 2010 |
| tax-EBITDA of a company (in Part 10) | section 406 |
| tax-interest expense amount of a company (in Part 10) | section 382 |
| tax-interest income amount of a company (in Part 10) | section 385 |
| trade (in Part 10) | section 1119 of CTA 2010 |
| total disallowed amount of a worldwide group (in Part 10) | section 373 |
| UK generally accepted accounting practice (in Part 10) | section 1127(2) of CTA 2010 |
| UK group company (in Part 10) | section 492 |
| UK property business (in Part 10) | Chapter 2 of Part 4 of CTA 2009 (applied by section 1119 of CTA 2010) |
| the UK sector of the continental shelf (in Chapter 8 of Part 10) | section 449(1) |
| the ultimate parent, of a worldwide group (in Part 10) | section 473(4)(b) |
| unexpired (in Chapter 4 of Part 10) | section 395 |
| United Kingdom (in Part 10) | section 1170 of CTA 2010 |
| used (in Chapter 4 of Part 10) | section 394 |
| within the charge to corporation tax (in Part 10) | section 1167 of CTA 2010 |
| wholly-owned subsidiary (in Part 10) | section 494(1) |
| a worldwide group (in Part 10) | section 473] |
Textual Amendments
F6Words in Sch. 11 Pt. 7 inserted (retrospectively) by Finance Act 2019 (c. 1), Sch. 11 paras. 21, 24
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