Taxation (International and Other Provisions) Act 2010 section 390

The worldwide group's aggregate net tax-interest expense and income

Section 390 defines how to calculate the worldwide group's aggregate net tax-interest expense and aggregate net tax-interest income for a period of account.

• The aggregate net tax-interest expense is the total of all group members' individual net tax-interest expenses minus the total of all group members' individual net tax-interest incomes, floored at nil if the result is negative.
• The aggregate net tax-interest income is the total of all group members' individual net tax-interest incomes minus the total of all group members' individual net tax-interest expenses, floored at nil if the result is negative.
• A relevant company for this purpose is any company that was a member of the worldwide group at any time during the period of account.
• Only one of the two aggregates — expense or income — can be a positive amount for any given period; the other will be nil.