Finance Act 2018 (c. 3)

SCHEDULES

SCHEDULE 8 U.K. Corporate interest restriction

PART 1 U.K. Amendments of Part 10 of TIOPA 2010

Hedging of tax-interest expense amounts or tax-interest income amounts etc U.K.

4 (1) Section 411 (“relevant expense amount” and “relevant income amount”) is amended as follows. U.K.

(2) In subsection (1)(e), for sub-paragraph (iii) substitute—

“(iii) losses in respect of risks arising in the ordinary course of a trade (other than risks arising in the ordinary course of a financial trade) where the derivative contract was entered into wholly for reasons unrelated to the capital structure of the worldwide group (or any member of the worldwide group);”.

(3) In subsection (2)(d), for sub-paragraph (iii) substitute—

“(iii) gains in respect of risks arising in the ordinary course of a trade (other than risks arising in the ordinary course of a financial trade) where the derivative contract was entered into wholly for reasons unrelated to the capital structure of the worldwide group (or any member of the worldwide group);”.