Taxation (International and Other Provisions) Act 2010 section 484

No actual financial statements: ultimate parent draws up financial statements

Section 484 addresses what happens for corporate interest restriction purposes when a worldwide group has no consolidated accounts, but the ultimate parent does prepare its own individual financial statements.

• Where the ultimate parent prepares its own financial statements but does not prepare consolidated accounts for a multi-company worldwide group, IAS (International Accounting Standards) financial statements are automatically treated as having been drawn up for that period.
• This deemed treatment applies for all purposes of the corporate interest restriction rules, except for this particular section itself.
• The ultimate parent can elect to disapply this automatic IAS treatment, but the election is irrevocable and cannot take effect for periods ending before the date the election is made.
• The election must specify a date from which it applies, and that date cannot be earlier than the day the election is made.