Taxation (International and Other Provisions) Act 2010 section 263

Net debt of a company

Section 263 defined the net debt of a company for the purposes of the worldwide debt cap rules, but has been repealed and replaced by the corporate interest restriction regime.

• Section 263 was part of the worldwide debt cap rules in Part 7 of TIOPA 2010, which limited the amount of tax-deductible financing costs for UK companies in multinational groups.
• The section provided the method for calculating the net debt of a company, being the excess of its relevant liabilities over its relevant assets.
• Part 7 (including section 263) was repealed by Finance (No. 2) Act 2017, which introduced the corporate interest restriction rules as a replacement regime.
• The repeal took effect for periods of account of worldwide groups beginning on or after 1 April 2017, meaning the old rules may still apply to earlier periods.