Taxation (International and Other Provisions) Act 2010 section 17

Interest allowance (non-consolidated investment) election

Section 17 allows the reporting company of a worldwide group to elect that the corporate interest restriction rules on group-interest and group-EBITDA should apply with adjustments for non-consolidated investments.

  • The reporting company may elect to apply the non-consolidated investment provisions, or revoke a previous election, for any period of account.
  • The election must specify one or more non-consolidated associates of the worldwide group to which the provisions will apply.
  • Each election or revocation takes effect only for the period of account in which it is made.
  • The non-consolidated investment provisions adjust how group-interest and group-EBITDA are calculated by reference to sections 427 and 428 of the Act.

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