Taxation (International and Other Provisions) Act 2010 section 294

Company tax returns

Section 294 dealt with company tax return requirements in connection with the worldwide debt cap rules, but has been repealed following the introduction of the corporate interest restriction regime.

  • Section 294 was part of Part 7 of TIOPA 2010, which contained the worldwide debt cap rules limiting the amount of tax-deductible finance expenses for UK members of large multinational groups.
  • The entire Part 7, including section 294, was repealed by Finance (No. 2) Act 2017, which replaced the worldwide debt cap with the corporate interest restriction rules.
  • The repeal took effect for periods of account of worldwide groups beginning on or after 1 April 2017.
  • For any periods of account that straddled the 1 April 2017 date or began before it, the old worldwide debt cap rules (including section 294) would still have applied.

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