Taxation (International and Other Provisions) Act 2010 section 319

Intra-group short-term finance: financing expense

Section 319 dealt with how to identify and measure financing expenses arising from short-term lending arrangements between companies in the same group, but has been repealed and replaced by the corporate interest restriction rules.

• Section 319 was part of the worldwide debt cap rules in Part 7 of TIOPA 2010, which limited the amount of financing expense a UK group could deduct for tax purposes.
• This section specifically addressed financing expenses connected with short-term finance arrangements between group companies, such as intra-group loans or cash pooling arrangements with a short duration.
• The entire Part 7 worldwide debt cap regime, including section 319, was repealed by Finance (No. 2) Act 2017 and replaced by the corporate interest restriction rules introduced by that Act.
• 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.