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Official guidance
Corporate Finance Manual

CFM97100 · Interest restriction: public infrastructure

  • CFM97110 · Outline
  • CFM97120 · Qualifying infrastructure activity
  • CFM97130 · Public infrastructure asset
  • CFM97140 · Public benefit test
  • CFM97150 · Expected economic life
  • CFM97160 · Group balance sheet test
  • CFM97170 · Buildings within UK property business
  • CFM97180 · Ancillary to, or facilitates, provision
  • CFM97190 · Qualifying infrastructure company
  • CFM97200 · The income test
  • CFM97210 · The asset test
  • CFM97220 · Fully taxed in the UK
  • CFM97230 · Decommissioning and decommissioning funds
  • CFM97240 · The election
  • CFM97250 · Elections for a transitional period
  • CFM97260 · Joint elections modifying the effect of an election to be qualifying infrastructure company
  • CFM97270 · Meaning of insignificant for members of a joint election
  • CFM97280 · One fails, all fail effect for members of a joint infrastructure election
  • CFM97290 · Effect of section 435 election on anti-cycling provisions
  • CFM97300 · Exemption for interest payable to third parties
  • CFM97320 · Limited recourse of financial instruments
  • CFM97330 · Guarantees, indemnities and financial assistance
  • CFM97335 · Loans advanced through non-resident intermediaries
  • CFM97340 · Qualifying old loan relationship
  • CFM97350 · Qualifying public receipts
  • CFM97360 · Highly predictable
  • CFM97370 · Ceasing to be a qualifying old loan relationship
  • CFM97380 · Amounts to be ignored or treated as nil
  • CFM97390 · Interaction with the ‘de minimis’ provisions
  • CFM97400 · Interaction with the transitional provisions
  • CFM97420 · Partnerships and transparent entities
  • CFM97430 · Relevant public body
  1. Interest restriction: public infrastructure
  2. Interest restriction: public infrastructure: expected economic life

CFM97150 | Interest restriction: public infrastructure: expected economic life

From HM Revenue & Customs · Corporate Finance Manual

TIOPA10/S436(2)(c) & (5)(c)

Expected economic life is a term specific to testing for qualifying infrastructure activity and is applied to both infrastructure of the UK and certain buildings which are part of a UK property business.

To be considered a public infrastructure asset an asset (which may be a building or part of a building) must have, have had, or be likely to have an expected economic life of ten years or more. This ten year limit is not limited by reference to the current owner.

Example 1

Company A constructs temporary accommodation for military barracks. It is expected at construction these will be unsuitable for use in 5-7 years. This accommodation has an expected economic life (EEL) of less than 10 years and would not be considered Infrastructure of the UK.

Example 2

Company B constructs an assault course at a different military barracks. This is considered to have useful life of 25 years. It has an EEL of greater than 10 years in Company B’s hands.

Company C acquires the assault course 20 years into its use. Even if this asset will cease to be of use in 5 years, it will still be considered an asset which had an EEL of greater than 10 years in Company C’s hands.

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