Taxation (International and Other Provisions) Act 2010 section 12

Elections

Section 12 sets out how certain elections under the corporate interest restriction rules must be made and revoked, and lists the seven types of election to which these requirements apply.

  • All listed elections must be made by including them in the interest restriction return for the relevant period of account (or the first period of account to which the election applies).
  • Where an election is capable of being revoked, the revocation must also be made through an interest restriction return for the relevant period.
  • Seven types of election are covered: group ratio, group ratio (blended), group-EBITDA (chargeable gains), interest allowance (alternative calculation), interest allowance (non-consolidated investment), interest allowance (consolidated partnerships), and abbreviated return.
  • The formal mechanism for both making and revoking these elections is always the interest restriction return — there is no separate standalone election process.

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