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Legislation
Taxation (International and Other Provisions) Act 2010

Crossheading Interest allowance

  • Section 396 The interest allowance of a worldwide group for a period of account
  • Section 397 Basic interest allowance calculated using fixed ratio method
  • Section 398 Basic interest allowance calculated using group ratio method
  • Section 399 The group ratio percentage
  • Section 400 The debt cap
  • Section 400A Carry forward of excess debt cap: new holding company
  1. Interest allowance
  2. Basic interest allowance calculated using group ratio method

Section 398 | Basic interest allowance calculated using group ratio method

From legislation.gov.uk

(1)For the purposes of section 396, the basic interest allowance of a worldwide group for a period of account of the group, calculated using the group ratio method, is the lower of the following amounts—

(a)the group ratio percentage of the aggregate tax-EBITDA of the group for the period;

(b)the group ratio debt cap of the group for the period.

(2)See—

section 399 for the meaning of “group ratio percentage”;

section 400 for the meaning of “group ratio debt cap”;

section 405 for the meaning of “aggregate tax-EBITDA”.

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