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FA 2019: corporate interest and debtor relationships

Schedule 11 makes a number of changes to the corporate interest restriction legislation that is contained in TIOPA 2010 Part 10 and which took effect from 1 April 2017. Most of the changes made by Sch 11 have been made to ensure that the legislation works as it was intended and appear to have been made in response to representations. The majority of such changes take effect for periods of account of worldwide groups beginning on or after 1 January 2019 as opposed to having retrospective effect. The changes are set out below.

The corporate interest restriction legislation has been amended to permit unused interest allowance and an excess debt cap amount to be carried forward where a new holding company is inserted between the ultimate holding company of the worldwide group and its shareholders (new TIOPA 2010 ss 395A and 400A respectively). These changes have been made by paras...

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