[F1Accounting period's pro-rata share of the total disallowed amountU.K.
Textual Amendments
F1Sch. 7A inserted (with effect in accordance with Sch. 5 para. 25(1)(2) of the amending Act) by Finance (No. 2) Act 2017 (c. 32), Sch. 5 para. 2 (with Sch. 5 para. 28)
24(1)This paragraph—U.K.
(a)applies in relation to a worldwide group that is subject to interest restrictions in a period of account of the group (“the relevant period of account”), and
(b)allocates the total disallowed amount of the group in the period of account to relevant accounting periods of companies that are UK group companies at any time during that period.
(2)The amount allocated to an accounting period under this paragraph is referred to in this Part of this Act as the accounting period's “pro-rata share” of the total disallowed amount.
(3)Sub-paragraph (4) applies where—
(a)a company's pro-rata share of the total disallowed amount is not nil, and
(b)the company has only one relevant accounting period.
(4)The amount of the total disallowed amount that is allocated to the accounting period is the company's pro-rata share of the total disallowed amount.
(5)Sub-paragraph (6) applies where—
(a)a company's pro-rata share of the total disallowed amount is not nil, and
(b)the company has more than one relevant accounting period.
(6)The amount of the total disallowed amount that is allocated to a relevant accounting period of the company is—
where—
A is the company's pro-rata share of the total disallowed amount;
B is the net tax-interest expense of the company for the accounting period;
C is the sum of the net tax-interest expenses of the company for each relevant accounting period.
(7)Where this paragraph does not allocate any of the total disallowed amount to an accounting period of a company, the accounting period's “pro-rata share” of the total disallowed amount is nil.
(8)For the purposes of this paragraph, the “net tax-interest expense” of a company for a relevant accounting period is—
(a)so much of the net tax-interest expense of the company for the relevant period of account as is referable to the accounting period, or
(b)if the amount determined under paragraph (a) is negative, nil.]