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Contents

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: relevant public body

CFM97430 | Interest restriction: public infrastructure: relevant public body

From HM Revenue & Customs · Corporate Finance Manual

TIOPA10/S491

A relevant public body for the purposes of the Corporate Interest Restriction means:

  • the Crown;

  • a Minister of the Crown;

  • a government department;

  • a Northern Ireland department;

  • a foreign sovereign power;

  • a designated educational establishment (within the meaning given by CTA09/S106);

  • a health service body (within the meaning given by CTA10/S986);

  • a local authority of local authority association;

  • any other body that acts under any enactment for public purposes and not for its own profit; or

  • any wholly owned subsidiary of any body falling within any of the above.

Enactment for these purposes includes:

  • an enactment contained in subordinate legislation within the meaning of the Interpretation Act 1978,

  • an enactment contained in, or in an instrument made under, an Act of the Scottish Parliament,

  • an enactment contained in, or in an instrument made under, a Measure or Act of the National Assembly for Wales, and

  • an enactment contained in, or in an instrument made under, Northern Ireland legislation.

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