Taxation (International and Other Provisions) Act 2010 section 317A

Companies with permanent establishments profits election

Section 317A, which previously dealt with elections relating to the profits of companies with permanent establishments, was repealed as part of the replacement of the old worldwide debt cap rules with the corporate interest restriction regime.

• Section 317A was part of Part 7 of TIOPA 2010, which contained the worldwide debt cap rules governing how much tax relief UK groups could claim for financing costs.
• The entire Part 7, including this section, was repealed by Finance (No. 2) Act 2017 as a consequence of the introduction of the corporate interest restriction rules.
• The repeal took effect for periods of account of worldwide groups beginning on or after 1 April 2017.
• Any worldwide group periods of account that started before 1 April 2017 would still have been subject to the old Part 7 rules, including this section, until those periods ended.