Taxation (International and Other Provisions) Act 2010 section 280

Statement of allocated disallowances: requirements

Section 280 set out the requirements for a statement of allocated disallowances under the former worldwide debt cap rules, but has been repealed for periods of account beginning on or after 1 April 2017.

• Section 280 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 groups that were part of worldwide groups.
• The section specified what information had to be included in a statement of allocated disallowances, which determined how any financing expense restriction was shared among the UK group companies.
• Part 7 of TIOPA 2010, including this section, was repealed by Finance (No. 2) Act 2017, which replaced the worldwide debt cap regime with the corporate interest restriction rules.
• The repeal took effect for periods of account of worldwide groups beginning on or after 1 April 2017, meaning the old rules may still apply to earlier periods that straddle that date.

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