Taxation (International and Other Provisions) Act 2010 section 335

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

Section 335 dealt with the treatment of group members whose income from property rental was subject to particular UK tax rules, as part of the worldwide debt cap provisions in Part 7 of the Act.

• Section 335 was part of the worldwide debt cap regime (Part 7 of TIOPA 2010), which limited the amount of tax-deductible financing costs for large groups
• The section specifically addressed how group members with UK property rental income, subject to particular tax treatment, were handled within the worldwide debt cap calculations
• The entire Part 7 worldwide debt cap regime, including section 335, was repealed by Finance (No. 2) Act 2017
• The repeal took effect for periods of account of worldwide groups beginning on or after 1 April 2017, with the worldwide debt cap being replaced by the corporate interest restriction rules