SolvedCFM96960 | Interest restriction: joint ventures: qualifying infrastructure company JV: effect on other companies
From HM Revenue & Customs · Corporate Finance Manual
Ordinarily for a qualifying infrastructure company (QIC) company tax-interest expense is exempt where it is attributable to a creditor which is itself a QIC.
However, this rule is disapplied where the creditor is a member of the JV group and the debtor company is not also in the JV worldwide group.
This prevents the interest paid on a loan owed to the JV group outside of the JV group being an exempt amount if the company paying the expense is a related to the lender company.