Taxation (International and Other Provisions) Act 2010 section 280A

Statement of allocated disallowances: dual resident investing companies

Section 280A previously required statements showing how expense disallowances were allocated to dual resident investing companies, but this provision has been repealed and replaced by the corporate interest restriction rules.

• Section 280A was part of Part 7 of TIOPA 2010, which dealt with the taxation of financing expenses for large groups of companies
• The section specifically addressed dual resident investing companies — companies that are tax resident in both the UK and another jurisdiction and hold investments
• The entire Part 7, including this section, was repealed by the Finance (No. 2) Act 2017 and replaced by the corporate interest restriction regime
• The repeal applies to periods of account of worldwide groups beginning on or after 1 April 2017