Corporation Tax Act 2010 section 357NI

Interest or other financing costs and receipts

Section 357NI prevents internal interest and financing transactions between a Northern Ireland Regional Establishment (NIRE) and other parts of the same company from affecting the calculation of NIRE profits.

• Interest or financing costs paid by the NIRE to another part of the same company cannot be deducted when calculating NIRE profits.
• Interest or financing income received by the NIRE from another part of the same company must not be included in NIRE profits.
• The rule applies to all types of financing costs and income, not just interest payments.
• The effect is to ensure that internal financing arrangements within a company do not artificially increase or reduce the profits attributable to the NIRE.