Taxation (International and Other Provisions) Act 2010 section 14

Group ratio (blended) election

Section 14 allows a reporting company to make a group ratio (blended) election where a related party investor belongs to a different worldwide group, enabling the interest allowance calculations to take into account the financial position of that investor's group.

• A group ratio (blended) election can be made where a related party investor is a member of a different worldwide group (an "investor worldwide group") throughout the period of account
• The election allows the reporting company to apply the blended group ratio provisions (sections 401 to 403) when calculating the group's interest allowance, and can also be revoked
• The election can specify one or more investor worldwide groups and can state that certain elections are to be treated as having or not having effect for periods of account of those investor groups
• Where a previous blended election treated an irrevocable election as having effect for an investor worldwide group, any subsequent blended election must continue to treat that irrevocable election as having effect