Taxation (International and Other Provisions) Act 2010 section 305A

Schemes preventing this Part applying to a large group

Section 305A was part of the worldwide debt cap rules (Part 7) that addressed anti-avoidance schemes designed to prevent the debt cap provisions from applying to large groups. This section has been repealed and replaced by the corporate interest restriction rules.

• Section 305A targeted arrangements where large groups attempted to structure themselves so that the worldwide debt cap rules in Part 7 would not apply to them.
• The provision was an anti-avoidance measure designed to counteract schemes that manipulated group structures to fall outside the scope of the debt cap legislation.
• Part 7 of the Taxation (International and Other Provisions) Act 2010, which contained this section, was repealed by the Finance (No. 2) Act 2017.
• The repeal took effect for periods of account of worldwide groups beginning on or after 1 April 2017, when the new corporate interest restriction regime replaced the old worldwide debt cap rules.

---