Taxation (International and Other Provisions) Act 2010 section 321

Short-term loan relationships

Section 321 previously defined the treatment of short-term loan relationships for the purposes of the worldwide debt cap rules, but has been repealed as part of the broader replacement of those rules by the corporate interest restriction regime.

• Section 321 formed part of Part 7 of TIOPA 2010, which dealt with the worldwide debt cap — a regime that limited the amount of tax-deductible financing costs for large multinational groups operating in the UK.
• The entire Part 7, including this section, was repealed by Finance (No. 2) Act 2017, section 20 and Schedule 5, paragraph 11.
• The repeal took effect for periods of account of worldwide groups beginning on or after 1 April 2017.
• The worldwide debt cap rules were replaced by the corporate interest restriction rules, which now govern the deductibility of corporate interest expenses for groups.