Part 1 Amendments of Part 10 of TIOPA 2010
Finance Act 2018 (2018 c 3) | Legislation

SCHEDULE 8 Corporate Interest Restriction

Section 24

Part 1 Amendments of Part 10 of TIOPA 2010

Introductory

1

Part 10 of TIOPA 2010 (corporate interest restriction) is amended as follows.

Hedging of tax-interest expense amounts or tax-interest income amounts etc

2

(1)     Section 384 (relevant derivative contract debits) is amended as follows.

(2)     In subsection (3), for paragraph (c) substitute—

“(c)     it is in respect of a risk arising in the ordinary course of a trade (other than a risk arising in the ordinary course of a financial trade) where the derivative contract was entered into wholly for reasons unrelated to the capital structure of the worldwide group (or any member of the worldwide group).â€

(3)     After subsection (3) insert—

“(3A)     For the purposes of subsection (3)(c) a debit is in respect of a risk arising in the ordinary course of “a financial trade†only so far as the risk relates to an amount which is or is likely to be—

(a)     a tax-interest expense amount, or

(b)     a tax-interest income amount,

of the company in any relevant accounting period.â€

3

(1)     Section 387 (relevant derivative contract credits) is amended as follows.

(2)     In subsection (3), for paragraph

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