Taxation (International and Other Provisions) Act 2010 section 339

Meaning of "ultimate parent"

Section 339 defined the term "ultimate parent" for the purposes of the worldwide debt cap rules in Part 7 of the Act, but this provision has been repealed and replaced by the corporate interest restriction regime.

• Section 339 provided the definition of "ultimate parent" used throughout the worldwide debt cap provisions in Part 7 of TIOPA 2010.
• The ultimate parent was the entity at the top of a worldwide group structure, which was central to determining how the debt cap rules applied to UK group companies.
• The entire Part 7 worldwide debt cap regime, including this definition, was repealed by Finance (No. 2) Act 2017.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 corporate interest restriction rules under Finance (No. 2) Act 2017 section 20 and Schedule 5 taking their place.