{
  "url": "https://openlegislation.uk/corporate-interest-restriction-consequential-amendments-regulations-2017/note",
  "json_url": "https://openlegislation.uk/corporate-interest-restriction-consequential-amendments-regulations-2017/note.json",
  "legislation": "uksi/2017/1227",
  "legislation_title": "The Corporate Interest Restriction (Consequential Amendments) Regulations 2017",
  "legislation_url": "https://openlegislation.uk/corporate-interest-restriction-consequential-amendments-regulations-2017",
  "path": "note",
  "kind": "note",
  "number": null,
  "heading": "Explanatory note",
  "text": "(This note is not part of the Regulations)\nThese Regulations make provision for consequential amendments in connection with new Part 10 of the Taxation (International and Other Provisions) Act 2010 (“TIOPA 2010”) inserted by the Finance (No. 2) Act 2017 which make provision for the restriction of relief for interest and finance costs of multinational companies.\nAuthority for the retrospective effect is given by paragraph 35 of Schedule 5 to the Finance (No. 2) Act 2017.\nRegulation 2 amends the Authorised Investment Funds (Tax) Regulations 2006 so that interest distributions, PAIF distributions (interest) and TEF distributions (non-dividend) paid by authorised investment funds are treated as not being a tax-interest expense amount for the purposes of Part 10 of TIOPA 2010.\nRegulation 3 amends the Taxation of Insurance Securitisation Companies Regulations 2007 so that for the purposes of Part 10 of TIOPA 2010, the net tax-interest income of a securitisation company is equal to the retained profit amount of the company and any management fee paid to another UK group company; any such management fee is treated as a negative amount of adjusted corporation tax earnings. Section 414(3)(b) (qualifying net group-interest expense, results dependent securities) of TIOPA 2010 is disapplied in relation to any interest paid or other distribution made by a securitisation company.\nRegulation 4 amends the Taxation of Insurance Securitisation Companies Regulations 2007 to disapply section 414(3)(b) (qualifying net group-interest expense, results dependent securities) of TIOPA 2010 in relation to any interest paid or other distribution made by an insurance securitisation company.\nRegulation 5 amends the Investment Trusts (Dividends) (Optional Treatment as Interest Distributions) Regulations 2009 so that interest distributions paid by an investment trust are treated as not being a tax-interest expense amount for the purposes of Part 10 of TIOPA 2010.\nA Tax Information and Impact Note covering this instrument was published on 5 December 2016 alongside the Finance Bill 2017 and is available on the website at https://www.gov.uk/government/collections/tax-information-and-impact-notes-tiins. It remains an accurate summary of the impacts that apply to this instrument.",
  "extent": null,
  "status": null,
  "version": "current",
  "annotations": [],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/uksi/2017/1227/note",
    "retrieved_at": "2026-10-28T23:05:05.320462+00:00"
  },
  "licence": "Open Government Licence v3.0",
  "licence_url": "https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/",
  "attribution": "Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives."
}