Taxation (International and Other Provisions) Act 2010 section 336A

Mismatches between tax treatment and accounting treatment

Section 336A previously addressed situations where the tax treatment of certain items did not align with their accounting treatment, but has been repealed as part of the replacement of the worldwide debt cap rules with the corporate interest restriction regime.

• Section 336A was part of Part 7 of TIOPA 2010, which dealt with the worldwide debt cap rules governing financing costs of large corporate groups.
• The entire Part 7, including this section, was repealed by the Finance (No. 2) Act 2017.
• The repeal took effect for periods of account of worldwide groups beginning on or after 1 April 2017.
• The corporate interest restriction rules introduced by Schedule 5 of the Finance (No. 2) Act 2017 replaced the former worldwide debt cap provisions.