Section 390 | The worldwide group's aggregate net tax-interest expense and income

(1)The “aggregate net tax-interest expense” of a worldwide group for a period of account of the group is (subject to subsection (2))—

(a)the total of the net tax-interest expense for the period of each relevant company that has such an amount, less

(b)the total of the net tax-interest income for the period of each relevant company that has such an amount.

(2)Where the amount determined under subsection (1) is negative, the “aggregate net tax-interest expense” of the group for the period is nil.

(3)The “aggregate net tax-interest income” of a worldwide group for a period of account of the group is (subject to subsection (4))—

(a)the total of the net tax-interest income for the period of each relevant company that has such an amount, less

(b)the total of the net tax-interest expense for the period of each relevant company that has such an amount.

(4)Where the amount determined under subsection (3) is negative, the “aggregate net tax-interest income” of the group for the period is nil.

(5)In this section “relevant company” means a company that was a member of the group at any time during the period of account of the group.

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