Taxation (International and Other Provisions) Act 2010 section 300

Meaning of "relevant associate"

Section 300 defined the term "relevant associate" for the purposes of the worldwide debt cap rules in Part 7 of TIOPA 2010, but this provision has been repealed and replaced by the corporate interest restriction rules.

  • Section 300 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 groups that were part of worldwide groups.
  • The section provided the definition of "relevant associate" โ€” a term used elsewhere in Part 7 to identify connected parties whose financing arrangements needed to be taken into account.
  • Part 7, including section 300, was repealed by Finance (No. 2) Act 2017 and replaced by the corporate interest restriction rules, which took a different approach to limiting interest deductions.
  • The repeal applies to periods of account of worldwide groups beginning on or after 1 April 2017, meaning the old worldwide debt cap rules may still be relevant for earlier periods.

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