Taxation (International and Other Provisions) Act 2010 section 264

Worldwide gross debt of worldwide group for period of account of the group

Section 264 defined how to calculate the worldwide gross debt of a worldwide group for a period of account, but has been repealed and replaced by the corporate interest restriction rules.

• Section 264 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 members of large multinational groups.
• The section set out how to determine the total gross debt of a worldwide group for a given period of account, which was a key component in applying the worldwide debt cap.
• The entire Part 7 of TIOPA 2010, including section 264, was repealed by Finance (No. 2) Act 2017, which introduced the corporate interest restriction regime as a replacement.
• The repeal takes effect for periods of account of worldwide groups beginning on or after 1 April 2017; the old worldwide debt cap rules continue to apply for earlier periods of account that straddle that date.