http://www.legislation.gov.uk/ukpga/2010/8/section/416Taxation (International and Other Provisions) Act 2010An Act to restate, with minor changes, certain enactments relating to tax; to make provision for purposes connected with the restatement of enactments by other tax law rewrite Acts; and for connected purposes.texttext/xmlenStatute Law Database2026-05-05Expert Participation2026-03-18 Part 10CHAPTER 74161For the purposes of this Part “the group-EBITDA” of a worldwide group for a period of account of the group (“the relevant period of account”) is— PBT + I + DAwhere—PBT is the group's profit before tax (which may be a negative amount) (see subsection (2));I is the net group-interest expense of the group for the period (which may be a negative amount) (see section 410); DA is the group's depreciation and amortisation adjustment (which may be a negative amount) (see subsection (3)).2For the purposes of this Chapter a worldwide group's “profit before tax” is—athe sum of the amounts that are recognised in the financial statements of the group for the period, as items of profit or loss, in respect of income of any description other than tax income, lessbthe sum of the amounts that are recognised in the financial statements of the group for the period, as items of profit or loss, in respect of expenses of any description other than tax expense.In this subsection “tax income” and “tax expense” have the meaning they have for accounting purposes.2AAn amount is not to be taken into account in calculating a worldwide group's profit before tax for the purposes of subsection (2) if it is, or relates to, an R&D expenditure credit under Chapter 1A of Part 13 of CTA 2009.3In this section the group's “depreciation and amortisation adjustment” means the sum of the following amounts (any of which may be negative)—athe capital (expenditure) adjustment (see section 417);bthe capital (fair value movement) adjustment (see section 418);cthe capital (disposals) adjustment (see section 419).4The following expressions have the same meaning in sections 417 to 419 as they have in this section—“the relevant period of account”;“the group's profit before tax”.5For provision affecting amounts recognised in financial statements in respect of certain profits or losses arising from derivative contracts, see section 420.Pt. 10: the existing Pt. 10 renumbered as Pt. 11 (except for ss. 375, 376 which are repealed), the existing ss. 372-374, 377-382 renumbered as ss. 499-507 and a new Pt. 10 (ss. 372-498) inserted (with effect in accordance with Sch. 5 para. 25(1)-(3) of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)Pt. 10 excluded by 2010 c. 4, s. 937NA (as inserted (with effect in accordance with Sch. 5 para. 25(1)(2) of the amending Act) by Finance (No. 2) Act 2017 (c. 32), Sch. 5 para. 7)Words in s. 416(2A) substituted (with effect in relation to accounting periods beginning on or after 1.4.2024) by Finance Act 2024 (c. 3), Sch. 1 paras. 14(4)(b), 16; S.I. 2024/286, reg. 2Pt. 10 excluded by 2010 c. 4, s. 938V(d) (as substituted (with effect in accordance with Sch. 5 para. 25(1)(2) of the amending Act) by Finance (No. 2) Act 2017 (c. 32), Sch. 5 para. 9)Pt. 10 excluded by 2010 c. 4, s. 938N(e) (as substituted (with effect in accordance with Sch. 5 para. 25(1)(2) of the amending Act) by Finance (No. 2) Act 2017 (c. 32), Sch. 5 para. 8)S. 416(2A) inserted (retrospectively) by Finance Act 2018 (c. 3), Sch. 8 paras. 6, 23(1)