Taxation (International and Other Provisions) Act 2010 section 324

Stranded management expenses in non-trading loan relationships: financing expense

Section 324 dealt with how stranded management expenses arising from non-trading loan relationships were treated as financing expenses under the worldwide debt cap rules, but this provision has been repealed and replaced by the corporate interest restriction regime.

• Section 324 was part of the worldwide debt cap rules in Part 7 of TIOPA 2010, which limited the amount of financing expense that UK groups could deduct for tax purposes.
• The section specifically addressed management expenses that became "stranded" — meaning they could not be used against current profits — where those expenses arose from non-trading loan relationships.
• The entire Part 7 worldwide debt cap regime, including section 324, was repealed by Finance (No. 2) Act 2017 and replaced by the corporate interest restriction rules introduced by section 20 and Schedule 5 of that Act.
• The repeal took effect for periods of account of worldwide groups beginning on or after 1 April 2017, meaning the worldwide debt cap rules may still be relevant for earlier periods.