Taxation (International and Other Provisions) Act 2010

329 The tested expense amount

(1) References in this Part to the “tested expense amount” for a period of account of the worldwide group are to the sum of the net financing deductions of each relevant group company.

(2) References in this Part to the “net financing deduction” of a company for a period of account of the worldwide group are to—

(a) the sum of the company’s financing expense amounts for the period (see section 313), less

(b) the sum of the company’s financing income amounts for the period (see section 314).

(3) References in subsection (2) to a company’s financing expense amounts or financing income amounts for a period of account of the worldwide group do not include any amount that arises as a result of a transaction that takes place at a time at which the company is not a relevant group company.

(4) If the amount determined in accordance with subsection (2) is negative, the net financing deduction of the company for the period is nil.

(5) If the amount determined in accordance with subsection (2) is small (see section 331), the net financing deduction of the company for the period is nil.