Taxation (International and Other Provisions) Act 2010 section 306

Schemes involving manipulation of rules in Chapter 2

Section 306 was an anti-avoidance provision targeting schemes that manipulated the worldwide debt cap rules, but has been repealed and replaced by the corporate interest restriction regime.

• Section 306 was part of the worldwide debt cap rules in Part 7 of TIOPA 2010, which limited the amount of tax-deductible financing costs for UK companies in large multinational groups.
• The section specifically targeted arrangements designed to manipulate the rules in Chapter 2 of Part 7, which dealt with how the worldwide debt cap was calculated and applied.
• The entire Part 7, including section 306, was repealed by Finance (No. 2) Act 2017, section 20 and Schedule 5, paragraph 11.
• The repeal took effect for periods of account of worldwide groups beginning on or after 1 April 2017, when the new corporate interest restriction rules replaced the worldwide debt cap regime.