Taxation (International and Other Provisions) Act 2010 Explanatory Notes

Section 308: Meaning of “relevant net deduction”

591.This section defines the “relevant net deduction” for the purposes of section 307(2). This is so much of the total disallowed amount (the tested expense amount less the available amount) as cannot be covered by a disregard of financing income of UK group companies. The relevant amount may be nil. The section is based on paragraph 49 of Schedule 15 to FA 2009.

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