Taxation (International and Other Provisions) Act 2010 section 281

Statement of allocated disallowances: effect

Section 281 dealt with the consequences that followed when a statement of allocated disallowances was made under the worldwide debt cap rules, determining how the disallowed amounts were applied to individual group companies.

• This section was part of the worldwide debt cap regime in Part 7 of TIOPA 2010, which limited the amount of tax-deductible financing costs for UK members of large multinational groups.
• It set out the practical effect of a statement of allocated disallowances, specifying how the total disallowed amount was attributed to and restricted the financing expense deductions of individual UK group companies.
• The entire Part 7 worldwide debt cap regime, including this section, was repealed and replaced by the corporate interest restriction rules introduced by Finance (No. 2) Act 2017.
• 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.