Skip to main content
Taxworld Logo
  • Membership
  • Tax Guide 2025–26 All Tax Guides Finance Act 2025 All Finance Acts See all publications →
  • Tax Planning for Non-Doms: Ireland 2024 See all events →
  • Blog Legislation
  • About Tax World Ireland 🇮🇪
Log in Get Started
Get Started
Taxworld Logo
Membership
Publications
Tax Guide 2025–26 All Tax Guides Finance Act 2025 All Finance Acts See all publications
Events
Tax Planning for Non-Doms: Ireland 2024 See all events
Resources
Blog Legislation
Company
About Tax World Ireland 🇮🇪
Log in Get Started

Taxation (International and Other Provisions) Act 2010

▸ Part 2 – Double taxation relief
  • ▸ Chapter 1 – Double taxation arrangements and unilateral relief arrangements
    • Double taxation arrangements
    • Unilateral relief arrangements
  • ▸ Chapter 2 – Double taxation relief by way of credit
    • Effect to be given to credit for foreign tax allowed against UK tax
    • Interpretation of Chapter
    • Credits where same income charged to income tax in more than one tax year
    • Cases in which credit not allowed
    • Exceptions to requirement to be UK resident
    • Calculating income or gains in respect of which credit is allowed
    • Limits on credit: general rules
    • Limit on, and reduction of, credit against income tax
    • Limit on credit against capital gains tax
    • Limit on total credit against income tax and capital gains tax
    • Limit on credit against corporation tax
    • Calculating tax for purposes of section 42(2)
    • Allocation of deductions etc to profits for purposes of section 42
    • Taking account of foreign tax underlying dividends
    • Taking account of tax underlying dividends that is not foreign tax
    • Tax underlying dividend treated as underlying tax paid by dividend's recipient
    • Tax underlying dividends: restriction of relief, and particular cases
    • Adjustment of foreign tax on profits of overseas permanent establishment
    • Unrelieved foreign tax on profits of overseas permanent establishment
    • Action after adjustment of amount payable by way of UK or foreign tax
    • Schemes and arrangements designed to increase relief: anti-avoidance
    • Insurance companies
  • ▸ Chapter 3 – Miscellaneous provisions
    • Application of Part for capital gains tax purposes
    • When foreign tax disregarded in applying Part for corporation tax purposes
    • Special rules for discretionary trusts
    • Deduction for foreign tax where no credit allowed
    • European cross-border transfers of business
    • European cross-border mergers
    • Transparent entities involved in cross-border transfers and mergers
    • Cross-border transfers and mergers: chargeable gains
    • Interpretation of sections related to the Mergers Directive
    • Cases about being taxed otherwise than in accordance with double taxation arrangements
    • The Arbitration Convention
    • International dispute-resolution instruments and agreements
    • Disclosure of information
    • Interpretation of double taxation arrangements
    • Assessments
▸ Part 3 – Double taxation relief for special withholding tax
  • ▸ Introductory
    • Section 135 – Relief under this Part: introductory
    • Section 136 – Interpretation of Part
  • ▸ Credit etc for special withholding tax
    • Section 137 – Income tax credit etc. for special withholding tax
    • Section 138 – Amount and application of the deemed tax under section 137
    • Section 139 – Capital gains tax credit etc. for special withholding tax
    • Section 140 – Provisions about the deemed tax under section 139
    • Section 141 – Credit under Chapter 2 of Part 2 to be allowed first
  • ▸ Calculation of income or gain on remittance basis where special withholding tax levied
    • Section 142 – Conditions for purposes of section 143
    • Section 143 – Taking account of special withholding tax in calculating income or gains
  • ▸ Certificates to avoid levy of special withholding tax
    • Section 144 – Issue of certificate
    • Section 145 – Refusal to issue certificate and appeal against refusal
▸ Part 4 – Transfer pricing
  • ▸ Chapter 1 – Basic transfer-pricing rule
    • Section 146 – Application of this Part
    • Section 147 – Tax calculations to be based on arm’s length, not actual, provision
    • Section 148 – The “participation condition”
  • ▸ Chapter 2 – Key interpretative provisions
    • Meaning of certain expressions that first appear in section 147
    • “Direct participation” in management, control or capital of a person
    • “Indirect participation” in management, control or capital of a person
    • Application of OECD principles
  • ▸ Chapter 3 – Exemptions from basic rule
    • Section 165 – Exemption for dormant companies
    • Section 166 – Exemption for small and medium-sized enterprises
    • Section 167 – Small and medium-sized enterprises: exceptions from exemption
    • Section 167A – Small enterprises: exception from exemption: transfer pricing notice
    • Section 168 – Medium-sized enterprises: exception from exemption: transfer pricing notice
    • Section 169 – Giving of transfer pricing notices
    • Section 170 – Appeals against transfer pricing notices
    • Section 171 – Tax returns where transfer pricing notice given
    • Section 172 – Meaning of “small enterprise” and “medium-sized enterprise”
    • Section 173 – Meaning of “qualifying territory” and “non-qualifying territory”
  • ▸ Chapter 4 – Position, if only one affected person potentially advantaged, of other affected person
    • Claim by affected person who is not advantaged
    • Claims: special cases
    • Alternative way of claiming if a security is involved
    • Notification to persons who may be disadvantaged
    • Treatment of interest where claim made
    • Treatment of interest where claim prevented by section 174A
    • Adjustment of double taxation relief where claim made
    • Interpretation of Chapter
  • ▸ Chapter 5 – Position of guarantor of affected person’s liabilities under a security issued by the person
    • Section 191 – When sections 192 to 194 apply
    • Section 192 – Attribution to guarantor company of things done by issuing company
    • Section 193 – Interaction between claims under sections 174 and 192(1)
    • Section 194 – Claims under section 192(1): general provisions
    • Section 192A – Provision for cases within Part 6A
  • ▸ Chapter 6 – Balancing payments
    • Section 195 – Qualifying conditions for purposes of section 196
    • Section 196 – Balancing payments between affected persons: no charge to, or relief from, tax
    • Section 197 – Qualifying conditions for purposes of section 198
    • Section 198 – Balancing payments by guarantor to issuer: no charge to, or relief from, tax
    • Section 199 – Pre-conditions for making election under section 200
    • Section 200 – Election to pay tax rather than make balancing payments
    • Section 201 – Pre-conditions for making election under section 202
    • Section 202 – Election, in guarantee case, to pay tax rather than make balancing payments
    • Section 203 – Elections under section 200 or 202
    • Section 204 – Meaning of “capital market condition” in sections 199 and 201
  • ▸ Chapter 7 – Oil-related ring-fence trades
    • Section 205 – Provision made or imposed between ring-fence trade and other activities
    • Section 206 – Meaning of “oil-related ring-fence trade” in sections 205 and 218
    • Section 206A – Modification of basic rule where allowances restricted for certain expenditure
  • ▸ Chapter 8 – Supplementary provisions and interpretation of Part
    • Unit trusts
    • Determinations requiring Commissioners' sanction
    • Appeals
    • Effect of Part on capital allowances and chargeable gains
    • Adjustments
    • Definitions
▸ Part 5 – Advance pricing agreements
  • Section 218 – Meaning of “advance pricing agreement”
  • Section 219 – Meaning of “associate” in section 218(2)(e)
  • Section 220 – Effect of agreement on party to it
  • Section 221 – Effect of revocation of agreement or breach of its conditions
  • Section 222 – Effect of agreement on non-parties
  • Section 223 – Application for agreement
  • Section 224 – Provision in agreement about years ended or begun before agreement made
  • Section 225 – Modification and revocation of agreement
  • Section 226 – Annulment of agreement for misrepresentation
  • Section 227 – Penalty for misrepresentation in connection with agreement
  • Section 228 – Party to agreement: duty to provide information
  • Section 229 – Modifications of agreement for double taxation purposes
  • Section 230 – Interpretation of Part: meaning of “Commissioners” and “officer”
▸ Part 6 – Tax arbitrage
  • ▸ Introduction
    • Section 231 – Overview
  • ▸ Deduction notices
    • Section 232 – Deduction notices
    • Section 233 – The deduction scheme conditions
    • Section 234 – Schemes achieving UK tax advantage for a company
    • Section 235 – Further provisions about deduction notices
  • ▸ Deduction schemes
    • Section 236 – Schemes involving hybrid entities
    • Section 237 – Instruments of alterable character
    • Section 238 – Shares subject to conversion
    • Section 239 – Securities subject to conversion
    • Section 240 – Debt instruments treated as equity
    • Section 241 – Scheme including issue of shares not conferring qualifying beneficial entitlement
    • Section 242 – Scheme including transfer of rights under a security
  • ▸ Consequences of deduction notices
    • Section 243 – Consequences of deduction notices
    • Section 244 – The rule against double deduction
    • Section 245 – Application of the rule against deduction for untaxable payments
    • Section 246 – Cases where payee’s non-liability treated as not a result of scheme
    • Section 247 – Cases where payee treated as having reduced liability as a result of scheme
    • Section 248 – The rule against deduction for untaxable payments
  • ▸ Receipt notices
    • Section 249 – Receipt notices
    • Section 250 – The receipt scheme conditions
    • Section 251 – Amounts within corporation tax
    • Section 252 – Further provisions about receipt notices
    • Section 253 – Exception for dealers
    • Section 254 – Rule for calculation or recalculation of income etc. following receipt notice
  • ▸ General provisions about deduction notices and receipt notices
    • Section 255 – Notices given before tax return made
    • Section 256 – Notices given after tax return made
    • Section 257 – Amendments, closure notices and discovery assessments where section 256 applies
  • ▸ Interpretation
    • Section 258 – Schemes and series of transactions
    • Section 259 – Minor definitions
▸ Part 1 – Overview
  • Section 1 – Overview of Act
▸ Part 6A – Hybrid and other mismatches
  • ▸ Chapter 1 – Introduction
    • Section 259A – Overview of Part
  • ▸ Chapter 2 – Key definitions
    • Meaning of “tax”
    • Equivalent provision to this Part under foreign law
    • Payments and quasi-payments etc.
    • Ordinary income
    • Hybrid entity etc.
    • Permanent establishments
  • ▸ Chapter 3 – Hybrid and other mismatches from financial instruments
    • Application of Chapter
    • Counteraction
    • Introduction
  • ▸ Chapter 4 – Hybrid transfer deduction/non-inclusion mismatches
    • Introduction
    • Application of Chapter
    • Counteraction
  • ▸ Chapter 5 – Hybrid payer deduction/non-inclusion mismatches
    • Introduction
    • Application of Chapter
    • Counteraction
  • ▸ Chapter 6 – Deduction/non-inclusion mismatches relating to transfers by permanent establishments
    • Introduction
    • Application of Chapter
    • Counteraction
  • ▸ Chapter 7 – Hybrid payee deduction/non-inclusion mismatches
    • Introduction
    • Application of Chapter
    • Counteraction
  • ▸ Chapter 8 – Multinational payee deduction/non-inclusion mismatches
    • Introduction
    • Application of Chapter
    • Counteraction
  • ▸ Chapter 9 – Hybrid entity double deduction mismatches
    • Introduction
    • Application of Chapter
    • Counteraction
  • ▸ Chapter 10 – Dual territory double deduction cases
    • Introduction
    • Application of Chapter
    • Counteraction
  • ▸ Chapter 11 – Imported mismatches
    • Introduction
    • Application of Chapter
    • Counteraction
  • ▸ Chapter 12 – Adjustments in light of subsequent events etc.
    • Section 259L – Adjustments where suppositions cease to be reasonable
    • Section 259LA – Deduction from taxable total profits where an amount of ordinary income arises late
    • Section 259LB – Adjustments in light of later treatment for accounting purposes
  • ▸ Chapter 13 – Anti-avoidance
    • Section 259M – Countering the effect of avoidance arrangements
  • ▸ Chapter 14 – Interpretation
    • Financial instruments
    • Relevant investment funds
    • Control groups and related persons
    • Qualifying institutional investors etc.
    • Partnerships
    • Securitisation companies
    • Priority
    • Relevant debt relief circumstances
    • Definitions
  • ▸ Chapter 12A – Allocation of dual inclusion income within group
    • Introduction
    • Application of Chapter
    • Allocation of DII surplus
    • Groups
    • “Dual inclusion income” and “counteraction amount”
  • ▸ Chapter 13A – Special provision concerning transparent funds
    • Section 259MA – Meaning of “transparent fund”
    • Section 259MB – Application of Chapters 3, 4, 5 and 7
    • Section 259MC – Application of Chapter 9
    • Section 259MD – Application of Chapter 11
▸ Part 7 – Tax treatment of financing costs and income
  • ▸ Chapter 1 – Introduction
    • Section 260 – Introduction
  • ▸ Chapter 2 – Application of Part
    • Section 261 – Application of Part
    • Section 262 – UK net debt of worldwide group for period of account of worldwide group
    • Section 263 – Net debt of a company
    • Section 264 – Worldwide gross debt of worldwide group for period of account of the group
    • Section 265 – References to amounts disclosed in balance sheet of company
    • Section 265A – Different accounting treatment used at company and group levels
    • Section 266 – Qualifying financial services groups
    • Section 267 – Qualifying activities
    • Section 268 – Lending activities and activities ancillary to lending activities
    • Section 269 – Insurance activities and insurance-related activities
    • Section 270 – Relevant dealing in financial instruments
    • Section 271 – UK trading income of the worldwide group
    • Section 272 – Worldwide trading income of the worldwide group
    • Section 273 – Foreign currency accounting
    • Section 273A – Meaning of “group securitisation company”
  • ▸ Chapter 3 – Disallowance of deductions
    • Section 274 – Application of Chapter and meaning of “total disallowed amount”
    • Section 275 – Meaning of “company to which this Chapter applies”
    • Section 275A – Meaning of “dual resident investing company”
    • Section 276 – Appointment of authorised company for relevant period of account
    • Section 277 – Meaning of “the reporting body”
    • Section 278 – Statement of allocated disallowances: submission
    • Section 279 – Statement of allocated disallowances: submission of revised statement
    • Section 280 – Statement of allocated disallowances: requirements
    • Section 280A – Statement of allocated disallowances: dual resident investing companies
    • Section 281 – Statement of allocated disallowances: effect
    • Section 282 – Company tax returns
    • Section 283 – Power to make regulations about statement of allocated disallowances
    • Section 284 – Failure of reporting body to submit statement of allocated disallowances
    • Section 284A – Section 284: supplementary
    • Section 285 – Powers to make regulations in relation to reductions under section 284
  • ▸ Chapter 4 – Exemption of financing income
    • Section 286 – Application of Chapter and meaning of “total disallowed amount”
    • Section 287 – Meaning of “company to which this Chapter applies”
    • Section 288 – Appointment of authorised company for relevant period of account
    • Section 289 – Meaning of “the reporting body”
    • Section 290 – Statement of allocated exemptions: submission
    • Section 291 – Statement of allocated exemptions: submission of revised statement
    • Section 292 – Statement of allocated exemptions: requirements
    • Section 293 – Statement of allocated exemptions: effect
    • Section 294 – Company tax returns
    • Section 295 – Power to make regulations about statement of allocated exemptions
    • Section 296 – Failure of reporting body to submit statement of allocated exemptions
    • Section 297 – Power to make regulations in relation to reductions under section 296
    • Section 298 – Balancing payments between group companies: no tax charge or relief
    • Section 298A – Application of Chapter to financing income amounts determined under section 314A
  • ▸ Chapter 5 – Intra-group financing income where payer denied deduction
    • Section 299 – Tax exemption for certain financing income received from EEA companies
    • Section 300 – Meaning of “relevant associate”
    • Section 301 – Meaning of “tax-resident” and “EEA territory”
    • Section 302 – Qualifying EEA tax relief for payment in current or previous period
    • Section 303 – Qualifying EEA tax relief for payment in future period
    • Section 304 – References to tax of a territory
    • Section 305 – Financing income amounts of a company
  • ▸ Chapter 6 – Tax avoidance
    • Section 305A – Schemes preventing this Part applying to a large group
    • Section 306 – Schemes involving manipulation of rules in Chapter 2
    • Section 307 – Schemes involving manipulation of rules in Chapters 3 and 4
    • Section 308 – Meaning of “relevant net deduction”
    • Section 309 – Calculation of amounts
    • Section 310 – Meaning of “carried-back amount” and “carried-forward amount”
    • Section 311 – Schemes involving manipulation of rules in Chapter 5
    • Section 312 – Meaning of “scheme” and “excluded scheme”
  • ▸ Chapter 7 – “Financing expense amount” and “financing income amount”
    • Section 313 – The financing expense amounts of a company
    • Section 314 – The financing income amounts of a company
    • Section 314A – The financing income amounts of a chargeable company under Part 9A
    • Section 315 – Interpretation of sections 313 and 314
    • Section 316 – Group treasury companies
    • Section 317 – Real estate investment trusts
    • Section 317A – Companies with permanent establishments profits election
    • Section 318 – Companies engaged in oil extraction activities
    • Section 319 – Intra-group short-term finance: financing expense
    • Section 320 – Intra-group short-term finance: financing income
    • Section 321 – Short-term loan relationships
    • Section 322 – Stranded deficits in non-trading loan relationships: financing expense
    • Section 323 – Stranded deficits in non-trading loan relationships: financing income
    • Section 324 – Stranded management expenses in non-trading loan relationships: financing expense
    • Section 325 – Stranded management expenses in non-trading loan relationships: financing income
    • Section 326 – Charities
    • Section 327 – Educational and public bodies
    • Section 328 – Interpretation of sections 316 to 327
    • Section 318A – Industrial and provident societies
  • ▸ Chapter 8 – “Tested expense amount” and “tested income amount”
    • Section 329 – The tested expense amount
    • Section 330 – The tested income amount
    • Section 331 – Companies with net financing deduction or net financing income that is small
    • Section 331A – Mismatches between tax treatment and accounting treatment
    • Section 331ZA – Elections disapplying sections 329(5) and 330(5)
  • ▸ Chapter 9 – “Available amount”
    • Section 332 – The available amount
    • Section 332A – Groups containing securitisation companies
    • Section 332B – Partnerships: expenses of borrowing
    • Section 332C – Partnerships: other expenses
    • Section 333 – Group members with income from oil extraction subject to particular tax treatment in UK
    • Section 334 – Group members with income from shipping subject to particular tax treatment in UK
    • Section 335 – Group members with income from property rental subject to particular tax treatment in UK
    • Section 336 – Meaning of accounting expressions used in this Chapter
    • Section 336A – Mismatches between tax treatment and accounting treatment
    • Section 332AA – Change of accounting standards: investment entities
  • ▸ Chapter 10 – Other interpretative provisions
    • Section 337 – The worldwide group
    • Section 338 – Meaning of “group”
    • Section 339 – Meaning of “ultimate parent”
    • Section 340 – Meaning of “corporate entity”
    • Section 341 – Meaning of “relevant non-corporate entity”
    • Section 342 – Treatment of entities stapled to corporate, or relevant non-corporate, entities
    • Section 343 – Treatment of business combinations
    • Section 344 – Meaning of “large” in relation to a group
    • Section 345 – Meaning of “UK group company” and “relevant group company”
    • Section 346 – Financial statements of the worldwide group
    • Section 347 – Non-compliant financial statements of the worldwide group
    • Section 348 – Non-existent financial statements of the worldwide group
    • Section 348A – Financial statements: business combinations to which the worldwide group is a party
    • Section 349 – References to amounts disclosed in financial statements
    • Section 350 – Translation of amounts disclosed in financial statements
    • Section 351 – Expressions taking their meaning from international accounting standards
    • Section 352 – Meaning of “relevant accounting period”
    • Section 353 – Other expressions
    • Section 353A – Effect of Part on parties to capital market arrangements
    • Section 353AA – Power to make regulations where accounting standards change
    • Section 353B – Regulations and orders
▸ Part 8 – Offshore funds etc.
  • ▸ Tax treatment of participants in offshore funds
    • Section 354 – Power to make regulations about tax treatment of participants
    • Section 355 – Meaning of “offshore fund”
    • Section 356 – Meaning of “mutual fund”
    • Section 357 – Exceptions to definition of “mutual fund”
    • Section 358 – Meaning of “relevant income-producing asset”
    • Section 359 – Power to make regulations about exceptions to definition of “mutual fund
  • ▸ Supplementary
    • Section 360 – Treatment of umbrella arrangements
    • Section 361 – Treatment of arrangements comprising more than one class of interest
    • Section 362 – Meaning of “participant” and “participation”
    • Section 363 – Meaning of “umbrella arrangements” and “part of umbrella arrangements”
    • Section 363A – Residence of undertakings for collective investment in transferable securities and alterative investment funds
▸ Part 9 – Amendments to relocate provisions of tax legislation
  • Section 364 – Oil activities
  • Section 365 – Alternative finance arrangements
  • Section 366 – Power to amend the alternative finance provisions
  • Section 367 – Leasing arrangements: finance leases and loans
  • Section 368 – Sale and lease-back etc
  • Section 369 – Factoring of income etc
  • Section 370 – UK representatives of non-UK residents
  • Section 371 – Miscellaneous relocations
▸ Part 9A – Controlled foreign companies
  • ▸ Chapter 2 – The CFC charge
    • Section 371BA – Introduction to the CFC charge
    • Section 371BB – The CFC charge gateway
    • Section 371BC – Charging the CFC charge
    • Section 371BD – Chargeable companies
    • Section 371BE – Companies which are managers of offshore funds etc
    • Section 371BF – Companies which are participants in offshore funds
    • Section 371BG – Companies holding shares as trading assets etc.
    • Section 371BH – Companies carrying on BLAGAB
    • Section 371BI – Banking companies
  • ▸ Chapter 3 – The CFC charge gateway: determining which (if any) of Chapters 4 to 8 applies
    • Section 371CA – Does Chapter 4 apply?
    • Section 371CB – Does Chapter 5 apply?
    • Section 371CC – Incidental non-trading finance profits: the 5% rule
    • Section 371CD – Incidental non-trading finance profits: the further 5% rule
    • Section 371CE – Does Chapter 6 apply?
    • Section 371CEA – Section 371CE: meaning of “group treasury company”
    • Section 371CF – Does Chapter 7 apply?
    • Section 371CG – Does Chapter 8 apply?
  • ▸ Chapter 1 – Overview
    • Section 371AA – Overview of Part
  • ▸ Chapter 4 – The CFC charge gateway: profits attributable to UK activities
    • Section 371DA – Introduction to Chapter
    • Section 371DB – The steps
    • Section 371DC – Exclusion: UK activities a minority of total activities
    • Section 371DD – Exclusion: economic value
    • Section 371DE – Exclusion: independent companies' arrangements
    • Section 371DF – Exclusion: trading profits (the basic rule)
    • Section 371DG – Exclusion: trading profits (business premises condition)
    • Section 371DH – Exclusion: trading profits (income condition)
    • Section 371DI – Exclusion: trading profits (management expenditure condition)
    • Section 371DJ – Exclusion: trading profits (IP condition)
    • Section 371DK – Exclusion: trading profits (export of goods condition)
    • Section 371DL – Exclusion: trading profits (anti-avoidance)
  • ▸ Chapter 5 – The CFC charge gateway: Non-trading finance profits
    • Section 371EA – The basic rule
    • Section 371EB – UK activities
    • Section 371EC – Capital investment from the UK
    • Section 371ED – Arrangements in lieu of dividends etc. to UK resident companies etc.
    • Section 371EE – Leases to UK resident companies etc.
  • ▸ Chapter 6 – The CFC charge gateway: trading finance profits
    • Section 371FA – The basic rule
    • Section 371FB – Qualifying loan relationships
    • Section 371FC – Loans from foreign permanent establishments of UK resident companies
    • Section 371FD – Exclusion: banking business
    • Section 371FE – Exclusion: insurance business
  • ▸ Chapter 7 – The CFC charge gateway: captive insurance business
    • Section 371GA – The basic rule
  • ▸ Chapter 8 – The CFC charge gateway: solo consolidation
    • Section 371HA – The basic rule
  • ▸ Chapter 9 – Exemptions for profits from qualifying loan relationships
    • Section 371IA – The basic rule
    • Section 371IB – Loans funded out of qualifying resources
    • Section 371IC – What is the “qualifying value” of “relevant pre-acquisition funds or other assets”?
    • Section 371ID – The 75% exemption
    • Section 371IE – Matched interest
    • Section 371IF – Determining the profits of a qualifying loan relationship
    • Section 371IG – What is a “qualifying loan relationship”?
    • Section 371IH – Exclusions from definition of “qualifying loan relationship”
    • Section 371II – Power to amend definitions
    • Section 371IJ – Claims
  • ▸ Chapter 22 – Supplementary provision
    • Section 371VA – Definitions
    • Section 371VB – Accounting periods
    • Section 371VC – Accounting profits
    • Section 371VD – Adjustments to accounting profits
    • Section 371VE – Cell companies etc.
    • Section 371VF – Connected persons etc.
    • Section 371VG – Finance profits
    • Section 371VH – Interests in companies
    • Section 371VI – Property business profits
    • Section 371VIA – Relevant finance leases
    • Section 371VJ – Regulations
  • ▸ Chapter 21 – Management
    • Section 371UA – Introduction to Chapter
    • Section 371UB – Application of the Taxes Acts to the CFC charge
    • Section 371UBA – Payments in respect of a charge on a banking company: information to be provided
    • Section 371UC – Just and reasonable apportionments
    • Section 371UD – Relief against sum charged
    • Section 371UE – Appeals affecting more than one person
    • Section 371UF – Recovery of sum charged from other UK resident companies
  • ▸ Chapter 20 – Residence of CFC's
    • Section 371TA – The basic rule
    • Section 371TB – How to determine the territory in which the CFC is resident
    • Section 371TC – Elections and designations about residence
  • ▸ Chapter 19 – Assumed taxable total profits, assumed total profits and the corporation tax assumptions
    • Overview
    • “Assumed taxable total profits” and “assumed total profits”
    • “The corporation tax assumptions”
  • ▸ Chapter 18 – Control
    • Section 371RA – Overview of Chapter
    • Section 371RB – Legal and economic control
    • Section 371RC – Legal and economic control: the 40% rule
    • Section 371RD – Legal and economic control: supplementary provision
    • Section 371RE – Control determined by reference to accounting standards
    • Section 371RF – Power to amend section 371RE etc.
    • Section 371RG – Companies in which a UK resident company has more than a 50% investment
  • ▸ Chapter 17 – Apportionment of a CFC's chargeable profit and creditable tax
    • Introduction
    • How are the apportionments to be made?
  • ▸ Chapter 16 – Creditable tax of a CFC
    • Section 371PA – What is “creditable tax”?
  • ▸ Chapter 15 – Relevant interests in a CFC
    • Introduction
    • What is a “relevant interest” in a CFC?
  • ▸ Chapter 14 – The tax exemption
    • Section 371NA – Introduction to Chapter
    • Section 371NB – The basic rule
    • Section 371NC – Reductions to “the local tax amount”
    • Section 371ND – What are “designer rate tax provisions”?
    • Section 371NE – How to determine “the corresponding UK tax”
  • ▸ Chapter 13 – The low profit margin exemption
    • Section 371MA – Introduction to Chapter
    • Section 371MB – The basic rule
    • Section 371MC – Anti-avoidance
  • ▸ Chapter 12 – The low profits exemption
    • Section 371LA – Introduction to Chapter
    • Section 371LB – The basic rule
    • Section 371LC – Anti-avoidance
  • ▸ Chapter 11 – The excluded territories exemption
    • Section 371KA – Introduction to Chapter
    • Section 371KB – The basic rule
    • Section 371KC – How to determine the territory in which a CFC is resident
    • Section 371KD – What is “the threshold amount”?
    • Section 371KE – Category A income: the basic rule
    • Section 371KF – Category A income: permanent establishments in excluded territories
    • Section 371KG – Category B income
    • Section 371KH – Category C income
    • Section 371KI – Category D income
    • Section 371KJ – The IP condition
  • ▸ Chapter 10 – The exempt period exemption
    • Section 371JA – Introduction to Chapter
    • Section 371JB – The basic rule
    • Section 371JC – When does an exempt period begin?
    • Section 371JD – How long is an exempt period?
    • Section 371JE – Adjustment of profits passing through the CFC charge gateway
    • Section 371JF – Anti-avoidance
    • Section 371JG – Amendment of company tax returns
▸ Part 10 – Corporate interest restriction
  • ▸ Chapter 1 – Introduction
    • Section 372 – Overview
    • Section 373 – Meaning of “subject to interest restrictions”, “the total disallowed amount” etc.
    • Section 374 – Interest restriction returns
  • ▸ Chapter 2 – Disallowance and reactivation of tax-interest expense amounts
    • Section 375 – Disallowance of deductions: full interest restriction return submitted
    • Section 376 – Disallowance of deductions: no return, or non-compliant return, submitted
    • Section 377 – Disallowance of deductions: identification of the tax-interest amounts to be left out of account
    • Section 378 – Disallowed tax-interest expense amounts carried forward
    • Section 379 – Reactivation of interest
    • Section 380 – Reactivation of deductions: identification of the tax-interest amounts to be brought into account
    • Section 381 – Set-off of disallowances and reactivations in the same accounting period
  • ▸ Chapter 3 – Tax-interest amounts
    • Tax-interest expense and income amounts: basic rules
    • Double taxation relief
    • Net tax-interest expense
    • Interpretation
  • ▸ Chapter 4 – Interest capacity
    • Section 392 – The interest capacity of a worldwide group for a period of account
    • Section 393 – Amount of interest allowance for a period that is “available” in a later period
    • Section 394 – When interest allowance is “used”
    • Section 395 – Amount of interest allowance for a period of account that is “unexpired” in later period
    • Section 395A – Carry forward of interest allowance: new holding company
  • ▸ Chapter 5 – Interest allowance
    • Interest allowance
    • Effect of group ratio (blended) election
  • ▸ Chapter 6 – Tax-EBITDA
    • Section 405 – The aggregate tax-EBITDA of a worldwide group
    • Section 406 – The tax-EBITDA of a company
    • Section 407 – Amounts not brought into account in determining a company’s tax-EBITDA
    • Section 408 – Excluded relevant intangibles debits and excluded relevant intangibles credits
    • Section 409 – Double taxation relief
  • ▸ Chapter 7 – Group-interest and group-EBITDA
    • Group-interest
    • Group-EBITDA
    • Treatment of derivative contracts in financial statements of worldwide group
    • Effect of group-EBITDA (chargeable gains) election
    • Effect of interest allowance (alternative calculation) election
    • Effect of interest allowance (non-consolidated investment) election
    • Effect of interest allowance (consolidated partnerships) election
    • Interpretation
  • ▸ Chapter 8 – Public infrastructure
    • Overview
    • Key concepts
    • Exemption and related provision
    • Supplementary
  • ▸ Chapter 9 – Cases involving particular types of company or business
    • Banking companies
    • Oil and gas
    • REITs
    • Insurance companies etc.
    • Investment managers
    • Shipping companies
    • Fair value accounting
    • Exemption for tax-interest expense or income amounts
    • Leases
  • ▸ Chapter 10 – Anti-avoidance
    • Section 461 – Counteracting effect of avoidance arrangements
  • ▸ Chapter 11 – Interpretation etc.
    • Related parties
    • Determining the worldwide group
    • Financial statements and periods of account
    • Other definitions
    • Regulations
▸ Part 11 – General provisions
  • ▸ Subordinate legislation
    • Section 499 – Orders and regulations
  • ▸ Interpretation
    • Section 500 – Abbreviated references to Acts
  • ▸ Final provisions
    • Section 501 – Minor and consequential amendments
    • Section 502 – Transitional provisions and savings
    • Section 503 – Repeals and revocations
    • Section 504 – Index of defined expressions
    • Section 505 – Extent
    • Section 506 – Commencement
    • Section 507 – Short title
▸ Schedules
  • Schedule 1 Oil activities: new Chapter 16A of Part 2 of ITTOIA 2005
  • ▸ Schedule 2 Alternative finance arrangements
    • Part 1 – New Part 10A of ITA 2007 (paras 1-26)
    • Part 2 – New Chapter 4 of Part 4 of TCGA 1992 (paras 27-45)
    • Part 3 – Other amendments (paras 46-55)
  • ▸ Schedule 3 Leasing arrangements: finance leases and loans
    • Part 1 – New Part 11A of ITA 2007 (paras 1-5)
    • Part 2 – New section 37A of TCGA 1992 (paras 6-7)
  • Schedule 4 Sale and lease-back etc.: new Part 12A of ITA 2007
  • Schedule 5 Factoring of income etc.: new Chapters 5B and 5C of Part 13 of ITA 2007
  • ▸ Schedule 6 UK Representatives of non-UK residents
    • Part 1 – New Chapters 2B and 2C of Part 14 of ITA 2007 (paras 1-23)
    • Part 2 – New Part 7A of TCGA 1992 (paras 24-33)
  • ▸ Schedule 7 Miscellaneous relocations
    • Part 1 – Relocation of section 38 of, and Schedule 15 to, FA 1973 (paras 1-10)
    • Part 2 – Relocation of section 24 of FA 1974 (paras 11-16)
    • Part 3 – Relocation of section 42 of ICTA (paras 17-24)
    • Part 4 – Relocation of section 84A of ICTA (paras 25-29)
    • Part 5 – Relocation of section 152 of ICTA (paras 30-34)
    • Part 6 – Relocation of section 337A(2) of ICTA (paras 35-39)
    • Part 7 – Relocation of section 475 of ICTA (paras 40-43)
    • Part 8 – Relocation of section 700 of ICTA (paras 44-47)
    • Part 9 – Relocation of section 787 of ICTA (paras 48-52)
    • Part 10 – Relocation of sections 130 to 132 of FA 1988 (paras 53-56)
    • Part 11 – Relocation of section 151 of FA 1989 (paras 57-62)
    • Part 12 – Relocation of Schedule 12 to F(No.2)A 1992 so far as applying for income tax purposes (paras 63-72)
    • Part 13 – Relocation of section 200 of FA 1996 so far as applying for income tax purposes (paras 73-77)
    • Part 14 – Relocation of section 36 of FA 1998 and section 111 of FA 2009 (paras 78-84)
    • Part 15 – Relocation of section 118 of FA 1998 (paras 85-93)
    • Part 16 – Relocation of section 144 of FA 2000 (paras 94-101)
    • Part 17 – Relocation of section 199 of FA 2003 (paras 102-106)
    • Part 18 – Relocation of section 61 of F(No.2)A 2005 (paras 107-110)
    • Part 19 – Relocation of paragraph 13 of Schedule 13 to FA 2007 (paras 111-115)
  • ▸ Schedule 7A Interest restriction returns
    • Part 1 – The reporting company (paras 1-11)
    • Part 2 – Contents of interest restriction return (paras 12-37)
    • Part 3 – Duty to keep and preserve records (paras 38-39)
    • Part 4 – Enquiry into interest restriction return (paras 40-55)
    • Part 5 – Determinations by officers of Revenue and Customs (paras 56-59)
    • Part 6 – Information powers exercisable by members of group (paras 60-61)
    • Part 7 – Information powers exercisable by officers of Revenue and Customs (paras 62-67)
    • Part 8 – Company tax returns (paras 68-73)
    • Part 9 – Supplementary (paras 74-76)
  • ▸ Schedule 8 Minor and consequential amendments
    • Part 1 – Double taxation relief (paras 1-105)
    • Part 2 – Transfer pricing and advance pricing agreements (paras 106-150)
    • Part 3 – Tax arbitrage (paras 151-155)
    • Part 4 – Tax treatment of financing costs and income (paras 156-160)
    • Part 5 – Offshore funds (paras 161-174)
    • Part 6 – Oil activities (paras 175-193)
    • Part 7 – Alternative finance arrangements (paras 194-229)
    • Part 8 – Leasing arrangements: finance leases and loans (paras 230-239)
    • Part 9 – Sale and lease-back etc. (paras 240-263)
    • Part 10 – Factoring of income etc. (paras 264-275)
    • Part 11 – UK representatives of non-UK residents (paras 276-286)
    • Part 12 – Amendments for purposes connected with other tax law rewrite Acts (paras 287-312)
    • Part 13 – General (para 313-332)
  • ▸ Schedule 9 Transitionals and savings etc.
    • Part 1 – General provisions (paras 1-9)
    • Part 2 – Changes in the law (para 10)
    • Part 3 – Double taxation relief (paras 11-27)
    • Part 4 – Transfer pricing (para 28)
    • Part 5 – Advance pricing agreements (para 29)
    • Part 6 – Tax avoidance (arbitrage) (para 30)
    • Part 7 – Tax treatment of financing costs and income (paras 31-32)
    • Part 8 – Offshore funds (paras 33-34)
    • Part 9 – Oil activities (paras 35-36)
    • Part 10 – Alternative finance arrangements (paras 37-40)
    • Part 11 – Sale and lease-back etc. (para 41)
    • Part 12 – Factoring of income etc. (para 42-44)
    • Part 13 – Miscellaneous relocations (para 45)
  • ▸ Schedule 10 Repeals and revocations
    • Part 1 – Double taxation relief
    • Part 2 – Transfer pricing and advance pricing agreements
    • Part 3 – Tax arbitrage
    • Part 4 – Tax treatment of financing costs and income
    • Part 5 – Offshore funds
    • Part 6 – Oil activities
    • Part 7 – Alternative finance arrangements
    • Part 8 – Leasing arrangements: finance leases and loans
    • Part 9 – Sale and lease-back etc.
    • Part 10 – Factoring of income etc.
    • Part 11 – UK representatives of non-UK residents
  • ▸ Schedule 11 Index of defined expressions used in Parts 2 to 8
    • Part 1 – Double taxation relief: index of defined expressions used in Parts 2 and 3
    • Part 2 – Transfer pricing: index of defined expressions used in Part 4
    • Part 3 – Advance pricing agreements: index of defined expressions used in Part 5
    • Part 4 – Tax arbitrage: index of defined expressions used in Part 6
    • Part 4A – Hybrid and other mismatches: index of defined expressions used in Part 6A
    • Part 5 – Tax treatment of financing costs and income: index of defined expressions used in Part 7
    • Part 6 – Offshore funds: index of defined expressions used in Part 8
    • Part 7 – Corporate interest restriction: index of defined expressions used in Part 10
Part 2 – Double taxation relief / Chapter 3 – Miscellaneous provisions / Interpretation of double taxation arrangements

Interpretation of double taxation arrangements

Contents

  • Section 130 – Interpreting provision about UK taxation of profits of foreign enterprises Section commentary
  • Section 130A – Interpreting provision about UK taxation of pensions etc. Section commentary
  • Section 131 – Interpreting provision about interest influenced by special relationship Section commentary
  • Section 132 – Interpreting provision about royalties influenced by special relationship Section commentary
  • Section 133 – Special relationship rule for royalties: matters to be shown by taxpayer Section commentary

Access full legislation.And much more.

By becoming a member, your team gets full access to Tax World research tools and source-backed tax resources.

Become a member

Access full legislation.And much more.

By becoming a member, your team gets full access to Tax World research tools and source-backed tax resources.

  • AI tax research with linked legislation and Finance Act changes
  • Commentary, official guidance, publications and training material
  • Case law, appeals and tribunal decisions in one place
Become a member
Taxworld Logo

Empowering your business.

We give accountants, tax consultants, financial advisers and legal advisers exactly what you need so you can solve problems like a pro.

Company

  • Membership
  • About
  • Taxworld Ireland 🇮🇪

Explore

  • Blog
  • Legislation
  • Publications
  • Events

© Copyright 2026 Taxworld

Privacy Policy | Cookies Policy | | Conditions of Use

We use optional analytics cookies to understand how people use our site. Cookie policy