Taxation (International and Other Provisions) Act 2010 section 494

Other interpretation

Section 494 provides definitions of key terms used throughout Part 10 of the Act (the corporate interest restriction rules) and clarifies how certain concepts apply for the purposes of those rules.

• The section defines important terms including fair value accounting, finance lease, right-of-use lease, service concession arrangement, and other expressions used in the corporate interest restriction provisions.
• It establishes that a non-corporate person can be treated as party to a loan relationship if they would qualify as such were they a company, ensuring the rules capture relevant financing arrangements regardless of the legal form of the participant.
• The definition of "insurance company" is extended so that it covers not only entities authorised under UK financial services legislation but also entities authorised under equivalent overseas regulatory regimes.
• Administrative terms are also defined, including "reporting company" (the company appointed to file on behalf of a worldwide group), "interest restriction return", and "the return period" (the group's period of account to which a return relates).