CFM98635 - Interest restriction: administration: UK group company: relevant accounting period.
TIOPA10/S490.
The corporate interest restriction computations are prepared for a worldwide group바카라 사이트檚 period of account. However, companies are taxed by reference to accounting periods, as defined in CTA09/S9-12. A UK group company바카라 사이트檚 accounting period will not necessarily coincide with its worldwide group바카라 사이트檚 period of account, so it is necessary to form a link between the two. Key to this linkage is the straightforward definition of a relevant accounting period in TIOPA10/S490:
바카라 사이트淔or the purposes of this Part a 바카라 사이트渞elevant accounting period바카라 사이트� of a company, in relation to a period of account of a worldwide group, means any accounting period that falls wholly or partly within the period of account of the worldwide group.바카라 사이트�
The guidance below sets out how amounts relating to a worldwide group바카라 사이트檚 interest restriction or reactivation cap for a period are given effect at the level of the UK group companies for the relevant accounting periods linked to that period of account.
Conversely, in computing the group바카라 사이트檚 aggregate tax-interest expense and aggregate tax-EBITDA, it is necessary to look at the amounts for each company바카라 사이트檚 relevant accounting periods, leaving out of account amounts that relate to disregarded periods that do not fall within the group바카라 사이트檚 period of account.