Taxation (International and Other Provisions) Act 2010 section 51

Return in relation to a worldwide group: other entities part of another group

Section 51 deals with what happens when an HMRC enquiry into one worldwide group's interest restriction return results in a new group being designated, and some of the UK companies in that new group already belong to an existing worldwide group with its own reporting company.

• When a closure notice designates a new worldwide group that includes UK companies already part of an existing group, HMRC must appoint the existing group's reporting company as reporting company for the new group within 30 days of the closure notice.
• Any interest restriction return already filed for the existing group is treated as withdrawn if its period of account overlaps with a designated period of account of the new group, along with any related enquiries, closure notices, appeals, or appeal determinations.
• If the existing group's withdrawn return covered a period starting before the new group's designated period, the appointment notice also serves to appoint the company for a shortened period of the existing group running up to the start of the new group's designated period.
• Where multiple enquiries are open at the same time and this paragraph could apply by reference to any of them, an HMRC officer must select whichever company they consider should be the reporting company for the new group.

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