Taxation (International and Other Provisions) Act 2010 section 331

Companies with net financing deduction or net financing income that is small

Section 331 provided an exemption from the worldwide debt cap rules for groups whose net financing deduction or net financing income was small, but this section has been repealed and replaced by the corporate interest restriction regime.

• Section 331 was part of the worldwide debt cap rules in Part 7 of the Taxation (International and Other Provisions) Act 2010, which limited the amount of financing costs that UK group companies could deduct for tax purposes.
• The section offered relief for groups with only small amounts of net financing deduction or net financing income, sparing them from the full complexity of the worldwide debt cap calculations.
• Part 7, including section 331, was repealed by the Finance (No. 2) Act 2017, which introduced the corporate interest restriction rules as a replacement regime.
• The repeal takes 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.