Taxation (International and Other Provisions) Act 2010 section 429

Meaning of "non-consolidated associate"

Section 429 defines what a "non-consolidated associate" of a worldwide group means for the purposes of the corporate interest restriction rules, identifying four categories of entity that qualify.

  • An entity is a non-consolidated associate if the ultimate parent's interest in it is accounted for in the group's financial statements as a joint venture or associate using the equity method or gross equity method.
  • A partnership qualifies as a non-consolidated associate if an interest allowance (consolidated partnership) election is in effect for the relevant period of account.
  • An entity that is a non-consolidated subsidiary of the ultimate parent at any time during the relevant period of account is also a non-consolidated associate.
  • A partnership or other transparent entity whose interest is accounted for in the group's financial statements on a fair value basis also qualifies as a non-consolidated associate.

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