Taxation (International and Other Provisions) Act 2010 section 26

"Amount available for reactivation" of company in period of account of group

Section 26 defines how to calculate the "amount available for reactivation" for a company within a worldwide group — that is, the amount of previously disallowed interest expense that can potentially be brought back into account in a given period.

• The amount available for reactivation is the lower of a calculated formula amount and the company's interest reactivation cap.
• The formula tracks cumulative disallowed interest brought forward, adds further disallowances from prior group periods (including from any previous worldwide group), and subtracts amounts already reactivated in those earlier periods.
• The calculation is anchored to a "specified accounting period," which is the company's earliest relevant accounting period, or, if it joined the group mid-period, the earliest period in which it was a member.
• The interest reactivation cap for the company equals the group's overall interest reactivation cap multiplied by the proportion of the period of account during which the company was a UK group company.

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