Taxation (International and Other Provisions) Act 2010

[F1398Basic interest allowance calculated using group ratio methodU.K.
This section has no associated Explanatory Notes

(1)For the purposes of section 396, the basic interest allowance of a worldwide group for a period of account of the group, calculated using the group ratio method, is the lower of the following amounts—

(a)the group ratio percentage of the aggregate tax-EBITDA of the group for the period;

(b)the group ratio debt cap of the group for the period.

(2)See—

  • section 399 for the meaning of “group ratio percentage”;

  • section 400 for the meaning of “group ratio debt cap”;

  • section 405 for the meaning of “aggregate tax-EBITDA”.]

Textual Amendments

F1Pt. 10: the existing Pt. 10 renumbered as Pt. 11 (except for ss. 375, 376 which are repealed), the existing ss. 372-374, 377-382 renumbered as ss. 499-507 and a new Pt. 10 (ss. 372-498) inserted (with effect in accordance with Sch. 5 para. 25(1)-(3) of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)