Taxation (International and Other Provisions) Act 2010 section 22

Statement of allocated interest restrictions

Section 22 sets out the requirements for the statement of allocated interest restrictions that must be included as part of a full interest restriction return, including how the group's total disallowed amount is divided among individual companies and their accounting periods.

• The statement must list UK group companies with net tax-interest expense, specify a disallowance amount for each, and show that these amounts total the group's overall disallowed amount.
• Each company's allocated disallowance cannot exceed its own net tax-interest expense, cannot be negative, and for non-consenting companies cannot exceed their pro-rata share of the total disallowed amount.
• Where a company has more than one relevant accounting period within the return period, the allocated disallowance must be further split across those periods, subject to similar caps and constraints.
• The sum of a company's allocated disallowances across its relevant accounting periods must equal its total allocated disallowance for the return period.

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