Part 1 New Part 10 of TIOPA 2010

SCHEDULE 5 Corporate Interest Restriction

Section 20

Part 1 New Part 10 of TIOPA 2010

1

In TIOPA 2010, after Part 9A insert—

“Part 10
Corporate Interest Restriction
Chapter 1
Introduction
372Ìý°¿±¹±ð°ù±¹¾±±ð·É

(1)     This Part contains provision that—

(a)     disallows certain amounts that a company would (apart from this Part) be entitled to bring into account for the purposes of corporation tax in respect of interest and other financing costs, and

(b)     allows certain amounts disallowed under this Part in previous accounting periods to be brought into account in later accounting periods.

(2)     In this Chapter—

(a)     section 373 defines some key concepts including, in particular, “the total disallowed amount†in relation to a period of account of a worldwide group, and

(b)     section 374 provides for Schedule 7A to have effect.

(3)     Chapter 2 provides for—

(a)     the disallowance in certain circumstances of tax-interest expense amounts of companies that are members of a worldwide group, and

(b)     the carrying forward of disallowed tax-interest expense amounts, and for bringing those amounts into account in certain circumstances in relation to a later period of account of the worldwide group.

(4)     Chapter 3—

(a)     defines “a tax-interest expense

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