# Taxation (International and Other Provisions) Act 2010, Paragraph 26

Extent: E+W+S+N.I.

(1) This paragraph applies for the purposes of this Part of this Act.
(2) The “amount available for reactivation” of a company in a period of account of a worldwide group (“the relevant worldwide group”) is—
(a) the amount determined under sub-paragraph (3), or
(b) if lower, the company's interest reactivation cap (see sub-paragraph (5)).
(3) The amount referred to in sub-paragraph (2)(a) is—
A+B−C+D−Ewhere—
A 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;
B 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;
C 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;
D 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;
E 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.
(4) In sub-paragraph (3) “the specified accounting period” means—
(a) the earliest relevant accounting period of the company, or
(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.
(5) For the purposes of sub-paragraph (2)(b) “the interest reactivation cap” of the company is—
A×Bwhere—
A is the interest reactivation cap of the worldwide group in the period of account;
B is the proportion of the period of account in which the company is a UK group company.

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Source: https://www.legislation.gov.uk/ukpga/2010/8/schedule/7A/paragraph/26 (the official version)
Page: https://openlegislation.uk/taxation-international-and-other-provisions-act-2010/schedule-7A/paragraph-26
Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives.