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SCHEDULES

SCHEDULE 8Corporate interest restriction

PART 1Amendments of Part 10 of TIOPA 2010

Hedging of tax-interest expense amounts or tax-interest income amounts etc

5In section 412 (section 411: interpretation), after subsection (3) insert—

(3A)For the purposes of section 411(1)(e)(iii) and (2)(d)(iii) losses or gains are in respect of risks arising in the ordinary course of “a financial trade” only so far as the risks relate to amounts which are or are likely to be—

(a)relevant expense amounts, or

(b)relevant income amounts,

of the worldwide group for any period of account.