Taxation (International and Other Provisions) Act 2010 section 278

Statement of allocated disallowances: submission

Section 278 required the submission of a statement showing how disallowed amounts under the worldwide debt cap rules were allocated among group companies, but this provision has been repealed.

• Section 278 was part of the worldwide debt cap rules in Part 7 of the Taxation (International and Other Provisions) Act 2010, which limited the amount of financing costs that UK group companies could deduct for tax purposes.
• The section dealt with the procedural requirement to submit a statement of allocated disallowances, setting out how any financing expense amounts disallowed at group level were distributed among the individual UK group companies.
• Part 7, including this section, was repealed by Finance (No. 2) Act 2017 and replaced by the corporate interest restriction rules introduced by section 20 and Schedule 5 of that Act.
• The repeal took effect for periods of account of worldwide groups beginning on or after 1 April 2017, meaning the worldwide debt cap rules may still be relevant for earlier periods.