C1Part 7Tax treatment of financing costs and income
CHAPTER 8“Tested expense amount” and “tested income amount”
331AF1Mismatches between tax treatment and accounting treatment
1
The Commissioners may make regulations for the purpose of altering the way in which the tested expense amount or the tested income amount is calculated in a case in which an accounts amount in respect of a matter is not equal to the tax amount in respect of that matter.
2
For this purpose—
a
the “accounts amount” in respect of a matter is—
i
the amount disclosed in the financial statements of the worldwide group in respect of the matter, or
ii
if no amount is so disclosed, nil, and
b
the “tax amount” in respect of a matter is—
i
the amount of the deduction to which a member of the worldwide group is entitled under a provision of the Corporation Tax Acts in respect of the matter,
ii
if more than one member is entitled to such a deduction, the total such deductions, or
iii
if no member is entitled to such a deduction, nil.
3
Regulations under this section may amend any provision of this Part.
4
Regulations under this section may have effect in relation to periods of account of the worldwide group beginning on or after the beginning of the calendar year in which the regulations are made.
5
Regulations under this section may include provision for the worldwide group to elect that the regulations (or any of them)—
a
are not to apply in relation to the group, or
b
are not to apply in relation to periods of account of the worldwide group beginning before the date on which the regulations are made.
Pt. 7 excluded by 2010 c. 4, s. 938N (as inserted (19.7.2011) by Finance Act 2011 (c. 11), Sch. 5 para. 2)