Taxation (International and Other Provisions) Act 2010 section 23

A company's pro-rata share of the total disallowed amount

Section 23 explains how the total disallowed amount of a worldwide group is divided among the individual UK group companies on a proportional basis.

• The total disallowed amount for a period of account is allocated among UK group companies that were members of the group at any time during that period.
• Each company's share is calculated in proportion to its net tax-interest expense relative to the total net tax-interest expense of all UK group companies with such expense.
• The formula used is: company's share = total disallowed amount × (company's net tax-interest expense ÷ sum of all companies' net tax-interest expense).
• If a company has no net tax-interest expense for the period, its pro-rata share of the total disallowed amount is nil.