Taxation (International and Other Provisions) Act 2010 section 310

Meaning of "carried-back amount" and "carried-forward amount"

Section 310 defined the terms "carried-back amount" and "carried-forward amount" for the purposes of the worldwide debt cap rules in Part 7 of the Act, but has been repealed and replaced by the corporate interest restriction regime.

• Section 310 was part of the worldwide debt cap provisions in Part 7 of TIOPA 2010, which limited the amount of finance expense that UK companies in large multinational groups could deduct for tax purposes.
• The section provided definitions of "carried-back amount" and "carried-forward amount", which were relevant to how unused or excess amounts under the worldwide debt cap were allocated across different accounting periods.
• The entire Part 7 worldwide debt cap regime, including section 310, was repealed by the Finance (No. 2) Act 2017 and replaced by the corporate interest restriction rules.
• The repeal took effect for periods of account of worldwide groups beginning on or after 1 April 2017, meaning the old rules may still be relevant for earlier periods.