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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. The group ratio percentage

Section 399 | The group ratio percentage

From legislation.gov.uk

(1)For the purposes of this Part “the group ratio percentage” of a worldwide group for a period of account of the group is (subject to subsection (2)) the following proportion expressed as a percentage—

Formula

AB

where—

A is the qualifying net group-interest expense of the group for the period;

B is the group-EBITDA of the group for the period.

(2)“The group ratio percentage” is 100% where—

(a)the percentage determined under subsection (1) is negative or higher than 100%, or

(b)B in that subsection is zero.

(3)See—

section 414 for the meaning of “qualifying net group-interest expense”;

section 416 for the meaning of “group-EBITDA”.

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