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Debt cap: regulations

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The Tax Treatment of Financing Costs and Income (Correction of Mismatches) Regulations, SI 2010/3025, are intended to address specific cases of mismatches between financing expense amounts and the ‘available amount’ in respect of the same financial arrangements, for the purpose of the debt cap provisions in TIOPA 2010 Part 7.

Those provisions set a ceiling on interest and other financing expenses for which corporation tax deductions are available to the UK members of a worldwide group of companies that are subject to corporation tax.