Taxation (International and Other Provisions) Act 2010 section 291

Statement of allocated exemptions: submission of revised statement

Section 291 allowed groups to submit a revised statement of how they had allocated their worldwide debt cap exemptions among group companies, but this provision has been repealed for accounting periods beginning on or after 1 April 2017.

• Section 291 was part of the worldwide debt cap rules in Part 7 of TIOPA 2010, which limited the amount of tax-deductible financing costs for UK members of large multinational groups.
• The section permitted a group to revise its statement of allocated exemptions — effectively allowing the group to change how it distributed its available financing expense exemption among its UK group companies.
• The entire Part 7 worldwide debt cap regime, including this section, was repealed by Finance (No. 2) Act 2017 and replaced by the corporate interest restriction rules introduced by that Act.
• The repeal takes effect for periods of account of worldwide groups beginning on or after 1 April 2017, meaning the old rules may still be relevant for earlier periods.