Taxation (International and Other Provisions) Act 2010 section 305

Financing income amounts of a company

Section 305 defined what constituted a company's "financing income amounts" for the purposes of the worldwide debt cap rules in Part 7 of TIOPA 2010, but this provision has been repealed and replaced by the corporate interest restriction regime.

• Section 305 was part of the worldwide debt cap rules in Part 7 of TIOPA 2010, which limited the amount of financing expense that UK companies in large multinational groups could deduct for tax purposes.
• The section identified and defined the types of income a company received that counted as "financing income amounts," essentially the counterpart to financing expense amounts within the same framework.
• The entire Part 7 worldwide debt cap regime, including section 305, was repealed by Finance (No. 2) Act 2017 and replaced by the corporate interest restriction rules introduced by section 20 and Schedule 5 of that Act.
• The repeal took effect for periods of account of worldwide groups beginning on or after 1 April 2017, meaning the worldwide debt cap rules may still be relevant for earlier periods that straddle or precede that date.