Taxation (International and Other Provisions) Act 2010 section 284

Failure of reporting body to submit statement of allocated disallowances

Section 284 dealt with the consequences when the reporting body of a worldwide group failed to submit the required statement showing how disallowed amounts were allocated among UK group companies, but this provision has been repealed.

• This section was part of Part 7 of TIOPA 2010, which contained the original worldwide debt cap rules governing how much tax relief UK members of large multinational groups could claim for their financing costs
• Section 284 specifically addressed what happened when the reporting body — the entity responsible for submitting returns on behalf of the group — did not file the statement of allocated disallowances within the required time
• The entire Part 7, including this section, was repealed by Finance (No. 2) Act 2017 and replaced by the corporate interest restriction rules, which introduced a different framework for limiting interest deductions
• The repeal took effect for periods of account of worldwide groups beginning on or after 1 April 2017, meaning Part 7 continued to apply to earlier periods