[423 Capitalised interest brought into account for tax purposes in accordance with GAAP]
Taxation (International and Other Provisions) Act 2010 (2010 c 8) | Legislation

[Effect of interest allowance (alternative calculation) election]

[423  Capitalised interest brought into account for tax purposes in accordance with GAAP]

[(1)     Where an interest allowance (alternative calculation) election (see paragraph 16 of Schedule 7A) has effect in relation to a period of account of a worldwide group (“the relevant period of account”), this Chapter applies in relation to the period subject to this section.

(2)     Section 413 (adjusted net group-interest expense of a worldwide group) has effect as if—

(a)     subsections (3)(a) and (4)(a) (which relate to capitalised interest) did not apply in relation to a GAAP-taxable asset or liability, and

(b)     subsections (3)(b) and (4)(b) (which relate to capitalised interest written off) did not apply in relation to a GAAP-taxable asset or liability.

[(2A)     Section 413 has effect, in the case of a GAAP-taxable

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