SCHEDULE 11 Corporate Interest Restriction
Finance Act 2019 (2019 c 1) | Legislation

SCHEDULE 11 Corporate Interest Restriction

Section 28

Introductory

1

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

Tax-interest amounts: amounts capitalised in intangible fixed assets

2

In Chapter 3 (tax-interest amounts), after section 391 insert—

“391A Amounts capitalised in carrying value of intangible fixed assets

In determining for the purposes of this Part whether an amount is a tax-interest expense amount or tax-interest income amount, section 906(1) of CTA 2009 (priority of intangible fixed asset rules) does not apply in respect of any matter which may be brought into account in accordance with Part 5 or 7 of that Act.â€

Carry forward of interest allowance: new holding company

3

After section 395 insert—

“395A Carry forward of interest allowance: new holding company

(1)     This section applies if—

(a)     a company (“Câ€) ceases to be the ultimate parent of a worldwide group (“the old groupâ€) because of a qualifying takeover, and

(b)     another company (“Nâ€) becomes the ultimate parent of a worldwide group (“the new groupâ€) as a result of the takeover.

(2)     For this purpose there is a qualifying takeover if there is a change in the ownership

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