SCHEDULES
SCHEDULE 5Non-UK resident companies carrying on UK property businesses etc
PART 2Supplementary & Consequential amendments
33TIOPA 2010
1
Section 415 (qualifying net group-interest expense: interpretation) is amended as follows.
2
In subsection (1) for paragraph (b) substitute—
b
either—
i
the condition in subsection (1A) is met, or
ii
any of the conditions in subsection (2) is met in relation to the guarantee, indemnity or other financial assistance in question”.
3
After subsection (1) insert—
1A
The condition is that—
a
the member in question is a company that has not been UK resident at any time before 29 October 2018,
b
the financial assistance in question is provided before that date, and
c
the financial assistance in question is in respect of a loan relationship, derivative contract or relevant arrangement or transaction (within the meaning of section 382(4)) to which the member in question is a party for the purposes of its UK property business.