Taxation (International and Other Provisions) Act 2010 section 25

Statement of allocated interest reactivations

Section 25 sets out the requirements for the statement of allocated interest reactivations that must be included in a full interest restriction return, specifying how previously disallowed interest amounts are distributed back to individual UK group companies.

  • The statement must list UK group companies, specify an allocated reactivation amount for each, and show the total of all such amounts.
  • Each company's allocated reactivation cannot exceed its own amount available for reactivation and cannot be negative.
  • The total of all allocated reactivations must equal either the sum of all companies' amounts available for reactivation, or the group's interest reactivation cap, whichever is lower.
  • The amount specified for each company is formally known as its "allocated reactivation" for the return period.

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