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Official guidance
Corporate Finance Manual

CFM91800 · Debt cap: failure to make statements of allocation

  • CFM91810 · Outline
  • CFM91820 · Default allocation of disallowance of financing expense amounts: no DRICs
  • CFM91825 · Default allocation of disallowance of financing expense amounts: DRICs involved
  • CFM91830 · Default allocation of disallowance of financing expense amounts: DRICs: formulae
  • CFM91835 · Default allocation of disallowance of financing expense amounts: DRICs: example
  • CFM91840 · Election for allocation of disallowance for company with multiple financing expense amounts
  • CFM91850 · Default allocation of disallowance for company with multiple financing expense amounts
  • CFM91860 · Default allocation of disallowance for company with multiple financing expense amounts: example
  • CFM91870 · Default treatment of financing income amounts
  • CFM91880 · Default treatment of exemption of financing income amounts: example
  • CFM91890 · Provision of information to group companies
  • CFM91900 · Worldwide group with more than one ultimate UK parent
  • CFM91910 · Information not provided to group companies
  • CFM91920 · Circumstances when a group company can make an amended return
  1. Debt cap: failure to make statements of allocation: Contents
  2. Debt cap: failure to make statements of allocation: default allocation of disallowance for company with multiple financing expense amounts: example

CFM91860 | Debt cap: failure to make statements of allocation: default allocation of disallowance for company with multiple financing expense amounts: example

From HM Revenue & Customs · Corporate Finance Manual

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

Company T and the default disallowance

In the example in CFM91820 Company T has a default reduction of £393,023. Its net financing deduction of £1,300,000 is made up of the following financing expense amounts (it has no financing income amounts):

  • Debt factoring costs £97,658

  • Non-trade loan relationship debits £213,267 (excluding exchange losses and any other debits excluded by TIOPA10/PT7/S313(3))

  • Trade loan relationship debits £85,984

  • Finance lease financing costs £903,091

If Company T does not make an election specifying any other allocation then the default allocation will be as in the table below:

Non trade loan relationship debits£213,267
Trade loan relationship debits£85,984
Finance lease financing costs£93,772
Debt factoring costs£nil
Total£393,023
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