Taxation (International and Other Provisions) Act 2010 section 342

Treatment of entities stapled to corporate, or relevant non-corporate, entities

Section 342 dealt with how entities that were "stapled" to corporate or relevant non-corporate entities should be treated for the purposes of the worldwide debt cap rules, but has been repealed.

• Section 342 was part of the worldwide debt cap provisions in Part 7 of TIOPA 2010, which limited the amount of tax-deductible financing costs for UK groups that were part of worldwide groups.
• The section addressed "stapled entities" — arrangements where the securities of two or more entities are linked so they can only be transferred together — and set out how these should be treated within the debt cap framework.
• The entire Part 7 worldwide debt cap regime, including section 342, was repealed by Finance (No. 2) Act 2017 and replaced by the corporate interest restriction rules.
• 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.