Corporation Tax Act 2010 section 937NA

Priority

Section 937NA establishes that the corporate interest restriction rules are to be disregarded when applying the provisions of Part 21A of the Corporation Tax Act 2010.

• When calculating amounts under Part 21A, the corporate interest restriction rules in Part 10 of TIOPA 2010 are treated as having no effect.
• This means Part 21A calculations proceed as though there were no cap or restriction on interest deductions under the corporate interest restriction regime.
• The provision ensures that Part 21A operates independently, without being reduced or adjusted by the separate corporate interest restriction framework.
• In practice, any restriction that would otherwise apply to a company's interest deductions under the corporate interest restriction rules is ignored for Part 21A purposes.