Taxation (International and Other Provisions) Act 2010 section 16

Interest allowance (alternative calculation) election

Section 16 allows the reporting company of a worldwide group to elect for an alternative method of calculating group-interest and group-EBITDA under the corporate interest restriction rules.

• The reporting company of a worldwide group may elect for the alternative calculation method to apply to the computation of group-interest and group-EBITDA.
• The election takes effect from the period of account for which it is made and continues for all subsequent periods of account.
• The election is irrevocable once made — it cannot be withdrawn or reversed.
• The alternative calculation provisions are those set out in sections 423 to 426, which deal with matters such as capitalised interest brought into account for tax purposes in accordance with GAAP and changes in accounting policy.