Taxation (International and Other Provisions) Act 2010 section 326

Charities

Section 326 previously provided rules relating to charities within the worldwide debt cap regime, but has been repealed and replaced by the corporate interest restriction rules.

• Section 326 was 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• The entire Part 7, including section 326, was repealed by the Finance (No. 2) Act 2017, which introduced the corporate interest restriction rules as a replacement.
• 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 began before 1 April 2017 would still have been subject to the old Part 7 rules, including section 326, until those periods concluded.