{
  "url": "https://openlegislation.uk/taxation-international-and-other-provisions-act-2010/schedule-7A/paragraph-26",
  "json_url": "https://openlegislation.uk/taxation-international-and-other-provisions-act-2010/schedule-7A/paragraph-26.json",
  "legislation": "ukpga/2010/8",
  "legislation_title": "Taxation (International and Other Provisions) Act 2010",
  "legislation_url": "https://openlegislation.uk/taxation-international-and-other-provisions-act-2010",
  "path": "schedule/7A/paragraph/26",
  "kind": "paragraph",
  "number": "26",
  "heading": null,
  "text": "(1) This paragraph applies for the purposes of this Part of this Act.\n(2) The “amount available for reactivation” of a company in a period of account of a worldwide group (“the relevant worldwide group”) is—\n(a) the amount determined under sub-paragraph (3), or\n(b) if lower, the company's interest reactivation cap (see sub-paragraph (5)).\n(3) The amount referred to in sub-paragraph (2)(a) is—\nA+B−C+D−Ewhere—\nA is the total of the disallowed tax-interest expense amounts (if any) that are brought forward to the specified accounting period from earlier accounting periods;\nB is the total of the tax-interest expense amounts (if any) that the company is required to leave out of account in the specified accounting period as a result of the operation of this Part of this Act in relation to a period of account of the worldwide group before the period of account;\nC is the total of the disallowed tax-interest expense amounts (if any) that the company is required to bring into account in the specified accounting period as a result of the operation of this Part of this Act in relation to a period of account of the worldwide group before the period of account;\nD is the total of the tax-interest expense amounts (if any) that the company is required to leave out of account in the specified accounting period as a result of the operation of this Part of this Act in relation to a period of account of a worldwide group of which the company was a member before it became a member of the relevant worldwide group;\nE is the total of the disallowed tax-interest expense amounts (if any) that the company is required to bring into account in the specified accounting period as a result of the operation of this Part of this Act in relation to a period of account of a worldwide group of which the company was a member before it became a member of the relevant worldwide group.\n(4) In sub-paragraph (3) “the specified accounting period” means—\n(a) the earliest relevant accounting period of the company, or\n(b) where the company became a member of the relevant worldwide group during the period of account, the earliest relevant accounting period of the company in which it was a member of the group.\n(5) For the purposes of sub-paragraph (2)(b) “the interest reactivation cap” of the company is—\nA×Bwhere—\nA is the interest reactivation cap of the worldwide group in the period of account;\nB is the proportion of the period of account in which the company is a UK group company.",
  "extent": "E+W+S+N.I.",
  "status": null,
  "version": "current",
  "annotations": [
    {
      "type": "F",
      "label": "F1",
      "text": "Sch. 7A inserted (with effect in accordance with Sch. 5 para. 25(1)(2) of the amending Act) by Finance (No. 2) Act 2017 (c. 32), Sch. 5 para. 2 (with Sch. 5 para. 28)"
    }
  ],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/ukpga/2010/8/schedule/7A/paragraph/26",
    "retrieved_at": "2026-10-29T09:10:17.008829+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."
}