Taxation (International and Other Provisions) Act 2010 section 479

"Financial statements" of a worldwide group

Section 479 defines what is meant by the "financial statements" of a worldwide group for the purposes of the corporate interest restriction rules, and signposts various override provisions that apply in special circumstances.

  • For a multi-company worldwide group, the financial statements are the consolidated accounts of the ultimate parent and its subsidiaries for the relevant period.
  • Where the worldwide group consists of a single company throughout the period, the financial statements are simply that company's own accounts for the period.
  • The basic rule is that the relevant financial statements are those actually drawn up by or on behalf of the ultimate parent, but several override provisions exist — for example, where accounts use non-qualifying accounting standards, consolidate the wrong subsidiaries, cover more than one worldwide group, or have not been prepared at all.
  • Financial statements drawn up for too long a period, or prepared too late, are disregarded entirely for the purposes of these rules.

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