Taxation (International and Other Provisions) Act 2010 section 18

Interest allowance (consolidated partnerships) election

Section 18 allows the reporting company of a worldwide group to elect that partnerships within the group are treated on a consolidated basis when calculating the group's interest allowance and EBITDA figures.

• The reporting company may elect for the consolidated partnership provisions to apply when calculating group-interest and group-EBITDA under Chapter 7 of Part 10.
• The election must specify one or more consolidated partnerships of the worldwide group, and further elections can be made later to add additional consolidated partnerships.
• Once made, the election takes effect for the relevant period of account and all subsequent periods, and it cannot be revoked.
• The detailed rules for how the consolidated partnership provisions operate are set out in section 430 of the Act.