Taxation (International and Other Provisions) Act 2010 section 293

Statement of allocated exemptions: effect

Section 293 dealt with the legal effect of a statement of allocated exemptions filed under the former worldwide debt cap rules, determining how exempt amounts were to be applied to individual UK group companies.

  • This section was part of the worldwide debt cap regime under Part 7 of TIOPA 2010, which limited the amount of tax-deductible financing costs for UK members of large multinational groups.
  • It set out what happened when a worldwide group filed a statement allocating available exempt amounts among its UK group companies.
  • The allocated exemptions reduced the financing expense amounts that would otherwise be disallowed for each relevant UK company.
  • The entire Part 7 worldwide debt cap regime, including this section, was repealed and replaced by the corporate interest restriction rules introduced by Finance (No. 2) Act 2017, effective for periods of account of worldwide groups beginning on or after 1 April 2017.

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