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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: worldwide group with more than one ultimate UK parent

CFM91900 | Debt cap: failure to make statements of allocation: worldwide group with more than one ultimate UK parent

From HM Revenue & Customs · Corporate Finance Manual

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

What happens if there is more than one ultimate UK parent

It is possible that a worldwide group may have more than one ultimate UK parent for the debt cap rules. For example, an overseas parent company may have two UK holding companies, each with a number of UK subsidiaries. In this case each ultimate UK parent is responsible for providing the information required by the group companies for which it is the only ultimate UK parent.

If, however, a company falls within the UK group of more than one ultimate UK parent (thus, in the example above, a company might be 60% owned by one UK holding company and 40% owned by the other), then each ultimate UK parent is responsible for meeting the obligations of the ultimate UK parent set out in the Regulations and TIOPA10/PT7.

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