Taxation (International and Other Provisions) Act 2010 section 10

Meaning of "consenting company" and "non-consenting company"

Section 10 defines what it means for a company to be a "consenting company" or a "non-consenting company" in relation to an interest restriction return submitted by a reporting company.

  • A company becomes a consenting company by notifying both HMRC and the reporting company that it wishes to be treated as such before the return is submitted.
  • A company can withdraw its consent by notifying the same parties that it no longer wishes to be a consenting company.
  • A company that has not given consent, or has withdrawn it before the return is submitted, is a "non-consenting company" in relation to that return.
  • Consent status is assessed at the point the interest restriction return is submitted, not at any later date.

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