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Contents

Legislation
Finance Act 2009

SCHEDULE 15 Tax treatment of financing costs and income

  • Part 1 Introduction
  • Part 2 Application of this Schedule
  • Part 3 Disallowance of deductions
  • Part 4 Exemption of financing income
  • Part 5 Intra-group financing income where payer denied deduction
  • Part 6 Anti-avoidance
  • Part 7 “Financing expense amount” and “financing income amount”
  • Part 8 The “tested expense amount” and “tested income amount”
  • Part 9 The “available amount”
  • Part 10 Other interpretative provisions
  • Part 11 Consequential amendments and commencement
  1. Finance Act 2009
  2. Tax treatment of financing costs and income

Schedule 15 | Tax treatment of financing costs and income

From legislation.gov.uk

Provision repealed

The source marks this provision as repealed and does not provide content for this version.

Part 1Introduction

Overview

(1)Repealed

Part 2Application of this Schedule

Application of Schedule

(2)Repealed

UK net debt of the worldwide group for period of account of worldwide group

(3)Repealed

Net debt of a company

(4)Repealed

Worldwide gross debt of worldwide group for period of account of worldwide group

(5)Repealed

References to amounts disclosed in balance sheet of relevant group company

(6)Repealed

Qualifying financial services groups

(7)Repealed

Qualifying activities

(8)Repealed

Lending activities and activities ancillary to lending activities

(9)Repealed

Insurance activities and insurance related activities

(10)Repealed

Relevant dealing in financial instruments

(11)Repealed

UK trading income of the worldwide group

(12)Repealed

Worldwide trading income of the worldwide group

(13)Repealed

Foreign currency accounting

(14)Repealed

Part 3Disallowance of deductions

Application of Part and meaning of “total disallowed amount”

(15)Repealed

Meaning of “company to which this Part applies”

(16)Repealed

Appointment of authorised company for relevant period of account

(17)Repealed

Meaning of “the reporting body”

(18)Repealed

Statement of allocated disallowances: submission

(19)Repealed

Statement of allocated disallowances: submission of revised statement

(20)Repealed

Statement of allocated disallowances: requirements

(21)Repealed

Statement of allocated disallowances: effect

(22)Repealed

Company tax returns

(23)Repealed

Power to make regulations about statement of allocated disallowances

(24)Repealed

Failure of reporting body to submit statement of allocated disallowances

(25)Repealed

Powers to make regulations in relation to reductions required under paragraph 25

(26)Repealed

Part 4Exemption of financing income

Application of Part and meaning of “total disallowed amount”

(27)Repealed

Meaning of “company to which this Part applies”

(28)Repealed

Appointment of authorised company for relevant period of account

(29)Repealed

Meaning of “the reporting body”

(30)Repealed

Statement of allocated exemptions: submission

(31)Repealed

Statement of allocated exemptions: submission of revised statement

(32)Repealed

Statement of allocated exemptions: requirements

(33)Repealed

Statement of allocated exemptions: effect

(34)Repealed

Company tax returns

(35)Repealed

Power to make regulations about statement of allocated exemptions

(36)Repealed

Failure of reporting body to submit statement of allocated exemptions

(37)Repealed

Power to make regulations in relation to reductions required under paragraph 37

(38)Repealed

Balancing payments between group companies: no charge to, or relief from, tax

(39)Repealed

Part 5Intra-group financing income where payer denied deduction

Exemption from tax for certain financing income received from certain EEA companies

(40)Repealed

Meaning of “relevant associate”

(41)Repealed

Meaning of “tax-resident” and “EEA territory”

(42)Repealed

Qualifying EEA tax relief for payment in the current period or a previous period

(43)Repealed

Qualifying EEA tax relief for payment in future period

(44)Repealed

References to tax of a territory

(45)Repealed

Financing income amounts of a company

(46)Repealed

Part 6Anti-avoidance

Schemes involving manipulation of rules in Part 2

(47)Repealed

Schemes involving manipulation of rules in Parts 3 and 4

(48)Repealed

Meaning of “relevant net deduction”

(49)Repealed

Calculation of amounts

(50)Repealed

Meaning of “carried-back amount” and “carried-forward amount”

(51)Repealed

Schemes involving manipulation of rules in Part 5

(52)Repealed

Meaning of “scheme” and “excluded scheme”

(53)Repealed

Part 7“Financing expense amount” and “financing income amount”

The financing expense amounts of a company

(54)Repealed

The financing income amounts of a company

(55)Repealed

Interpretation of paragraphs 54 and 55

(56)Repealed

Group treasury companies

(57)Repealed

Real estate investment trusts

(58)Repealed

Companies engaged in oil extraction activities

(59)Repealed

Intra-group short-term finance: financing expense

(60)Repealed

Intra-group short-term finance: financing income

(61)Repealed

Short-term loan relationships

(62)Repealed

Stranded deficits in non-trading loan relationships: financing expense

(63)Repealed

Stranded deficits in non-trading loan relationships: financing income

(64)Repealed

Stranded management expenses in non-trading loan relationships: financing expense

(65)Repealed

Stranded management expenses in non-trading loan relationships: financing income

(66)Repealed

Charities

(67)Repealed

Educational and public bodies

(68)Repealed

Interpretation of paragraphs 57 to 68

(69)Repealed

Part 8The “tested expense amount” and “tested income amount”

The tested expense amount

(70)Repealed

The tested income amount

(71)Repealed

Companies with net financing deduction or net financing income that is small

(72)Repealed

Part 9The “available amount”

The available amount

(73)Repealed

Group members with income from oil extraction subject to particular tax treatment in UK

(74)Repealed

Group members with income from shipping subject to particular tax treatment in UK

(75)Repealed

Group members with income from property rental subject to particular tax treatment in UK

(76)Repealed

Meaning of accounting expressions used in this Part

(77)Repealed

Part 10Other interpretative provisions

The worldwide group

(78)Repealed

Meaning of “group”

(79)Repealed

Meaning of “ultimate parent”

(80)Repealed

Meaning of “corporate entity”

(81)Repealed

Meaning of “relevant non-corporate entity”

(82)Repealed

Treatment of entities stapled to corporate entities or relevant non-corporate entities

(83)Repealed

Treatment of business combinations

(84)Repealed

Meaning of “large” in relation to a group

(85)Repealed

Meaning of “UK group company” and “relevant group company”

(86)Repealed

Financial statements of the worldwide group

(87)Repealed

Non-compliant financial statements of worldwide group

(88)Repealed

Non-existent financial statements of worldwide group

(89)Repealed

References to amounts disclosed in financial statements

(90)Repealed

Translation of amounts disclosed in financial statements into sterling

(91)Repealed

Expressions taking their meaning from international accounting standards

(92)Repealed

Meaning of “relevant accounting period”

(93)Repealed

Meaning of “the Commissioners” and “HMRC”

(94)Repealed

Part 11Consequential amendments and commencement

Consequential amendments

(95)Repealed

(96)Repealed

Commencement

(97)Repealed

Anti-avoidance: change of period of account of worldwide group

(98)Repealed

Transitional provision

(99)Repealed

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