Commentary

D1.1418 Corporate interest restriction—calculating aggregate net tax-expense or income

Corporate tax
Corporate tax | Commentary

D1.1418 Corporate interest restriction—calculating aggregate net tax-expense or income

Corporate tax | Commentary

D1.1418 Corporate interest restriction—calculating aggregate net tax-expense or income

This calculation applies to any company within the charge to corporation tax that was a member of the group at any time during the period of account of that worldwide group1.

A group cannot have both aggregate net-tax interest income and aggregate net-tax interest expense in a single period of account: it will have one or the other. Most groups will have aggregate net tax-expense calculated as follows2:

  1.  

    •     the sum of the net tax-interest expense of all relevant companies in a net tax-interest expense position, less

  2.  

    •     the sum of the

To continue reading
View the latest version of this document, as well as thousands of others like it, sign in to TolleyLibrary or register for a free trial