What did section 334 of TIOPA 2010 deal with?

Section 334 of TIOPA 2010 addressed how group members with shipping income subject to particular UK tax treatment, such as the tonnage tax regime, should be handled within the worldwide debt cap framework. It ensured such income was appropriately accounted for when calculating deductible interest limits for large corporate groups.

Why was section 334 of TIOPA 2010 repealed?

Section 334 was repealed as part of the removal of the entire worldwide debt cap regime in Part 7 of TIOPA 2010. The Finance (No. 2) Act 2017 replaced it with the corporate interest restriction rules, which take a different approach to limiting interest deductions for large corporate groups operating in the United Kingdom.

When did the repeal of section 334 TIOPA 2010 take effect?

The repeal takes effect for periods of account of worldwide groups beginning on or after 1 April 2017. For worldwide group periods of account that straddled this date, having started before 1 April 2017, the old worldwide debt cap rules including section 334 would still have applied for that period.

What replaced the worldwide debt cap rules including section 334?

The worldwide debt cap was replaced by the corporate interest restriction regime, introduced by section 20 and Schedule 5 of the Finance (No. 2) Act 2017. This new regime takes a different approach to limiting tax-deductible interest expenses for large corporate groups, superseding the old Part 7 TIOPA 2010 provisions entirely.

Taxation (International and Other Provisions) Act 2010 section 334

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

Section 334 previously dealt with the treatment of group members whose shipping income received particular tax treatment in the UK, but this provision has been repealed.

Section 334 was part of Part 7 of TIOPA 2010, which contained rules about the worldwide debt cap for large corporate groups
The section specifically addressed how group members with shipping income that was subject to special UK tax treatment should be handled within the worldwide debt cap framework
The entire Part 7, including section 334, was repealed by the Finance (No. 2) Act 2017 and replaced by the corporate interest restriction rules
The repeal takes effect for periods of account of worldwide groups beginning on or after 1 April 2017

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