Taxation (International and Other Provisions) Act 2010 section 267

Qualifying activities

Section 267 previously defined qualifying activities for the purposes of the worldwide debt cap rules in Part 7 of the Act, but this section has been repealed and replaced by the corporate interest restriction regime.

• Section 267 was part of the worldwide debt cap provisions in Part 7 of TIOPA 2010, which limited the amount of tax-deductible financing costs for UK companies in large multinational groups.
• The entire Part 7, including this section, was repealed by Finance (No. 2) Act 2017, section 20 and Schedule 5, paragraph 11.
• The repeal took effect for periods of account of worldwide groups beginning on or after 1 April 2017.
• The worldwide debt cap rules were replaced by the corporate interest restriction rules, which now govern the extent to which corporate interest expense and other financing costs can be deducted for tax purposes.