Taxation (International and Other Provisions) Act 2010 section 393

Amount of interest allowance for a period that is "available" in a later period

Section 393 determines how much of a worldwide group's unused interest allowance from an earlier accounting period (the originating period) can be carried forward and made available in a later accounting period (the receiving period).

  • The available amount carried forward is the lower of two figures: the amount not yet used up (Amount A) and the amount not yet expired under the five-year time limit (Amount B)
  • Amount A is the original interest allowance for the originating period, minus any amounts already used in that period or in any intervening periods before the receiving period
  • Amount B is the portion of the originating period's interest allowance that has not yet expired by the time of the receiving period, reflecting the five-year carry-forward limit
  • No interest allowance is available from an earlier period if a full interest restriction return has not been submitted for the originating period, the receiving period, or any period in between, or if an abbreviated return election applies to any of those periods

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