Taxation (International and Other Provisions) Act 2010 section 440

Loans etc. made by qualifying infrastructure companies to be ignored

Section 440 provides that a qualifying infrastructure company's tax-interest income amounts are disregarded for the purposes of the corporate interest restriction rules.

• This section applies where a company qualifies as a qualifying infrastructure company for the whole of an accounting period.
• It also requires that the company would otherwise have had tax-interest income amounts in that accounting period.
• Where both conditions are met, the company is treated as if it had no tax-interest income amounts for that period.
• The effect is to exclude the company's interest income from the corporate interest restriction calculations entirely.