What did section 314 of TIOPA 2010 do?

Section 314 defined the financing income amounts of a company under the worldwide debt cap rules in Part 7 of the Taxation (International and Other Provisions) Act 2010. It identified income received from financing arrangements, which was used when calculating a multinational group's overall UK net debt position for tax purposes.

When was section 314 of TIOPA 2010 repealed?

Section 314 was repealed by Finance (No. 2) Act 2017 under section 20 and Schedule 5, paragraph 11. The repeal applies to periods of account of worldwide groups beginning on or after 1 April 2017. From that date, the corporate interest restriction rules replaced the entire Part 7 worldwide debt cap regime.

What replaced the worldwide debt cap rules including section 314?

The corporate interest restriction rules introduced by Finance (No. 2) Act 2017 section 20 and Schedule 5 replaced the worldwide debt cap regime. These new rules take a different approach to limiting interest and other financing cost deductions for corporation tax purposes for UK companies within multinational groups.

Were there transitional provisions when section 314 was repealed?

Groups whose accounting periods straddled 1 April 2017 may have needed to consider both the worldwide debt cap rules and the new corporate interest restriction rules during the transitional period. The repeal applied to periods of account of worldwide groups beginning on or after 1 April 2017, so earlier periods remained under the old regime.

Taxation (International and Other Provisions) Act 2010 section 314

The financing income amounts of a company

Section 314 defined the financing income amounts of a company for the purposes of the worldwide debt cap rules, but has been repealed and replaced by the corporate interest restriction regime.

Section 314 was part of the worldwide debt cap rules in Part 7 of TIOPA 2010, which limited the amount of financing expense deductions available to UK members of multinational groups.
The section set out how to determine the financing income amounts of a company, which were relevant to calculating the net debt position of the UK group.
The entire Part 7 worldwide debt cap regime, including this section, was repealed by Finance (No. 2) Act 2017.
The repeal took effect for periods of account of worldwide groups beginning on or after 1 April 2017, with the corporate interest restriction rules under Finance (No. 2) Act 2017 section 20 and Schedule 5 taking its place.

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