C1C3C2F1Part 10F1Corporate interest restriction
Pt. 10 excluded by 2010 c. 4, s. 937NA (as 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. 7)
Pt. 10 excluded by 2010 c. 4, s. 938V(d) (as substituted (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. 9)
Pt. 10 excluded by 2010 c. 4, s. 938N(e) (as substituted (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. 8)
F1CHAPTER 7Group-interest and group-EBITDA
Group-interest
410Net group-interest expense
1
For the purposes of this Part the “net group-interest expense” of a worldwide group for a period of account of the group (“the relevant period of account”) is—
where—
A is the sum of the relevant expense amounts that are recognised in the financial statements of the group for the period as items of profit or loss;
B is the sum of the relevant income amounts that are recognised in the financial statements of the group for the period as items of profit or loss.
2
Subsection (3) applies where—
a
a relevant expense amount (“the capitalised expense”) is brought into account in financial statements of the group (whether for the relevant period of account or any earlier period) in determining the carrying value of an asset,
b
the asset is not a relevant asset, and
c
in the financial statements of the group for the relevant period of account, any of the carrying value is written down.
3
A in subsection (1) is treated as including so much of the amount written down as is attributable to the capitalised expense.
4
Subsection (5) applies where—
a
a relevant income amount (“the capitalised income”) is brought into account in financial statements of the group (whether for the relevant period of account or any earlier period) in determining the carrying value of an asset,
b
the asset is not a relevant asset, and
c
in the financial statements of the group for the relevant period of account, any of the carrying value is written down.
5
B in subsection (1) is treated as including the amount of the reduction in the amount written down that is attributable to the capitalised income.
F25A
If, on the assumption that subsections (3) and (5) applied to relevant assets, an amount would, in accordance with subsection (3) or (5), have been treated as included in A or B in subsection (1)—
a
as an amount attributable to the capitalised expense, or
b
as an amount attributable to the capitalised income,
none of that amount is to be included in A or B in that subsection.
6
See—
section 411 for the definitions of “relevant expense amount” and “relevant income amount”;
section 417(5) and (6) for the definition of “relevant asset”;
section 420 for provision affecting amounts recognised in financial statements in respect of certain profits or losses arising from derivative contracts.
Pt. 10: the existing Pt. 10 renumbered as Pt. 11 (except for ss. 375, 376 which are repealed), the existing ss. 372-374, 377-382 renumbered as ss. 499-507 and a new Pt. 10 (ss. 372-498) inserted (with effect in accordance with Sch. 5 para. 25(1)-(3) of the amending Act) by Finance (No. 2) Act 2017 (c. 32), Sch. 5 para. 1, 10(1)(2)(a)(3) (with Sch. 5 paras. 27, 32-34)