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Contents

Official guidance
Corporate Finance Manual

CFM90600 · Debt Cap: gateway test

  • CFM90610 · Introduction
  • CFM90615 · Debt Cap Gateway test: CTSA returns
  • CFM90620 · Test based around period of account of the worldwide group
  • CFM90630 · UK net debt derived from financial statements of group companies
  • CFM90640 · UK permanent establishments
  • CFM90650 · Group companies with different accounting periods to that of the worldwide group
  • CFM90655 · The accounting periods of companies joining or leaving a group
  • CFM90660 · Worldwide gross debt derived from group consolidated financial statements
  • CFM90670 · Group does not prepare consolidated financial statements
  • CFM90680 · UK net debt derived from financial statements of group companies
  • CFM90690 · De minimis limit
  • CFM90700 · Calculation of worldwide gross debt
  • CFM90710 · Definition of relevant liabilities - short and long term borrowings
  • CFM90715 · Definition of relevant liabilities: UK permanent establishments
  • CFM90718 · Definition of relevant liabilities - finance leases and ‘quasi loans’
  • CFM90720 · Definition of relevant assets
  • CFM90730 · Calculation of gateway test using the presentation currency of the group
  • CFM90740 · Application of the gateway test: examples
  1. Debt Cap: gateway test: contents
  2. Debt cap: gateway test: de minimis limit

CFM90690 | Debt cap: gateway test: de minimis limit

From HM Revenue & Customs · Corporate Finance Manual

This guidance applies to worldwide group periods of account ending before or straddling 1 April 2017.

Where the net debt amount for a relevant group company is less than £3 million then the net debt amount is deemed to be nil

TIOPA10/S262 (3) deems the net debt amount of a relevant group company to be nil, if the calculated amount is less than £3 million. This means that relevant group or group securitisation companies with small amounts of average net debt can be excluded from the gateway test.

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