Taxation (International and Other Provisions) Act 2010 section 307

Schemes involving manipulation of rules in Chapters 3 and 4

Section 307 was an anti-avoidance provision designed to counter schemes that manipulated the worldwide debt cap rules, but has been repealed and replaced by the corporate interest restriction regime.

• Section 307 targeted arrangements that sought to exploit or manipulate the detailed rules in Chapters 3 and 4 of Part 7, which governed how the worldwide debt cap operated
• The provision formed part of the wider worldwide debt cap regime, which limited the amount of tax-deductible financing costs that UK companies in a multinational group could claim
• The entire Part 7 of TIOPA 2010, including section 307, was repealed by the Finance (No. 2) Act 2017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 rules came into force