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Legislation
Taxation (International and Other Provisions) Act 2010

Crossheading Effect of interest allowance (non-consolidated investment) election

  • Section 427 Group interest and group-EBITDA
  • Section 428 Section 427: associated worldwide groups
  • Section 429 Meaning of “non-consolidated associate”
  1. Effect of interest allowance (non-consolidated investment) election
  2. Section 427: associated worldwide groups

Section 428 | Section 427: associated worldwide groups

From legislation.gov.uk

(1)This section has effect for the purposes of section 427 and this section.

(2)“Associated worldwide group” means the worldwide group of which a specified non-consolidated associate is the ultimate parent.

(3)Where (apart from this subsection) a specified non-consolidated associate does not fall within section 473(1)(a) (conditions for being the ultimate parent of a worldwide group), it is treated as if it did fall within that provision.

(4)Where (apart from this subsection) financial statements of an associated worldwide group are not drawn up in respect of the relevant period of account, IAS financial statements of the associated worldwide group are treated as having been drawn up in respect of that period.

(5)The associated worldwide group's financial statements for the relevant period of account are treated as if no relevant expense amounts were recognised in them, as items of profit or loss, so far as they relate to financial liabilities owed to any member of the principal worldwide group by any member of the associated worldwide group.

(6)The reference in section 427(6) to profits or losses of the associated worldwide group to which the principal worldwide group is entitled does not include any profits or losses that relate to times when the non-consolidated associate is a member of the principal worldwide group.

(7)Subsection (8) has effect in the application of this Part (for the purposes mentioned in subsection (1)) in relation to the financial statements of an associated worldwide group for the relevant period of account.

(8)The associated worldwide group is treated—

(a)as having made an interest allowance (alternative calculation) election if and only if such an election has effect in relation to the relevant period of account of the principal worldwide group, and

(b)as not having made any other election under this Part.

(9)In this section “specified” means specified in the interest allowance (non-consolidated investment) election.

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