Section 389 | The “net tax-interest expense” or “net tax-interest income” of a company

(1)A company has “net tax-interest expense” for a period of account of a worldwide group if the total of its tax-interest expense amounts for the period exceeds the total of its tax-interest income amounts for the period.

(2)The amount of the net tax-interest expense of the company for the period is the amount of the excess.

(3)A company has “net tax-interest income” for a period of account of a worldwide group if the total of its tax-interest income amounts for the period exceeds the total of its tax-interest expense amounts for the period.

(4)The amount of the net tax-interest income of the company for the period is the amount of the excess.

(5)The net tax-interest expense or net tax-interest income of a company for a period of account of a worldwide group is “referable” to an accounting period of the company to the extent that it comprises tax-interest expense amounts or tax-interest income amounts that are (or apart from this Part would be) brought into account in the accounting period.

(6)This section applies for the purposes of this Part.