Taxation (International and Other Provisions) Act 2010 section 333

Group members with income from oil extraction subject to particular tax treatment in UK

Section 333 dealt with how group members earning income from oil extraction activities were treated where that income was subject to particular UK tax rules, as part of the worldwide debt cap provisions in Part 7 of the Act.

• This section formed part of the worldwide debt cap regime (Part 7 of TIOPA 2010), which limited the amount of tax-deductible financing costs for large multinational groups operating in the UK.
• It addressed the specific treatment of group companies that derived income from oil extraction activities in the UK, recognising that such income was already subject to a special tax regime (including the supplementary charge on ring-fence profits).
• The entire Part 7 worldwide debt cap regime, including this section, was repealed and replaced by the corporate interest restriction rules introduced by Finance (No. 2) Act 2017.
• 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.