Taxation (International and Other Provisions) Act 2010 section 268

Lending activities and activities ancillary to lending activities

Section 268 defined what counted as lending activities and ancillary lending activities for the purposes of the worldwide debt cap rules, but has been repealed and replaced by the corporate interest restriction regime.

• Section 268 was part of Part 7 of TIOPA 2010, which contained the worldwide debt cap provisions designed to limit UK tax deductions for financing costs.
• The section provided definitions of lending activities and activities ancillary to lending, which were relevant to how certain financial businesses were treated under the debt cap rules.
• The entire Part 7, including this section, was repealed by Finance (No. 2) Act 2017, section 20 and Schedule 5, paragraph 11.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, with the corporate interest restriction rules replacing the worldwide debt cap from that date.