Taxation (International and Other Provisions) Act 2010 section 266

Qualifying financial services groups

Section 266 defined what constituted a "qualifying financial services group" for the purposes of the worldwide debt cap rules, but this provision has been repealed and replaced by the corporate interest restriction regime.

  • Section 266 was part of the Part 7 worldwide debt cap rules, which limited the amount of tax-deductible finance costs for large groups of companies.
  • A qualifying financial services group was a group where financial services activities (such as banking, insurance, or fund management) formed a significant part of the group's business.
  • Groups that qualified as financial services groups were subject to modified rules under the worldwide debt cap, recognising that borrowing and lending is central to their commercial operations.
  • The entire Part 7 worldwide debt cap regime, including section 266, was repealed for periods of account of worldwide groups beginning on or after 1 April 2017 and replaced by the corporate interest restriction rules introduced by Finance (No. 2) Act 2017.

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