Taxation (International and Other Provisions) Act 2010 section 405

The aggregate tax-EBITDA of a worldwide group

Section 405 defines how to calculate the aggregate tax-EBITDA for a worldwide group, which is a key figure used in determining the corporate interest restriction.

• The aggregate tax-EBITDA is the total of the individual tax-EBITDAs of every company that was a member of the worldwide group at any point during the period of account.
• If the combined total of all member companies' tax-EBITDAs is a negative figure, the aggregate tax-EBITDA is treated as nil rather than negative.
• This aggregate figure is used in calculating the basic interest allowance under both the fixed ratio method and the group ratio method.
• The calculation covers all companies that were group members at any time during the period, not just those that were members for the entire period.