Taxation (International and Other Provisions) Act 2010 section 353A

Effect of Part on parties to capital market arrangements

Section 353A, which addressed how Part 7 of the Act applied to parties involved in capital market arrangements, has been repealed and replaced by the corporate interest restriction rules.

• Section 353A was part of the worldwide debt cap rules in Part 7 of TIOPA 2010, which limited the amount of tax-deductible financing expenses for large multinational groups operating in the UK.
• The entire Part 7, including this section, was repealed by the Finance (No. 2) Act 2017, which introduced the corporate interest restriction regime as a replacement.
• The repeal takes effect for periods of account of worldwide groups beginning on or after 1 April 2017.
• For any periods of account that straddled 1 April 2017 (i.e. began before that date), the old worldwide debt cap rules, including section 353A, would still have applied.