{
  "url": "https://openlegislation.uk/taxation-international-and-other-provisions-act-2010/section-192",
  "json_url": "https://openlegislation.uk/taxation-international-and-other-provisions-act-2010/section-192.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": "section/192",
  "kind": "section",
  "number": "192",
  "heading": "Attribution to guarantor company of things done by borrower",
  "text": "(1) On the making of a claim, the guarantor company is, to the extent of the reduction mentioned in subsection (1)(c) of section 191 (so far as it meets the condition in subsection (1)(d) of that section), to be treated for all purposes of the Taxes Acts as if it (and not the borrower)—\n(a) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .\n(b) was the person that owed the borrowing liabilities under the borrowing transaction, and\n(c) had paid any interest or other amounts paid under it by the borrower.\n(2) Subsection (1) is subject to subsection (3).\n(3) Where the borrower’s liabilities under the borrowing transaction are the subject of two or more guarantees (whether or not provided by the same person), TD must not exceed TR, where—\nTD is the total of the amounts brought into account by the guarantor companies because of subsection (1), and\nTR is the total amount of the reductions within section 191(1)(c).\n(4) Provision about claims under subsection (1) is made by—\nsection 193 (interaction between claims under subsection (1) and claims under section 174), and\nsection 194 (general provision about claims under subsection (1)).\n(5) In subsection (1) “the Taxes Acts” has the meaning given by section 118(1) of TMA 1970.\n(6) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .",
  "extent": null,
  "status": null,
  "version": "current",
  "annotations": [
    {
      "type": "F",
      "label": "F1",
      "text": "Words in s. 192(1) substituted (with effect in accordance with Sch. 6 para. 12 of the amending Act) by Finance Act 2026 (c. 11), Sch. 6 paras. 7(3)(a)(i), 12"
    },
    {
      "type": "F",
      "label": "F2",
      "text": "Word in s. 192(1) substituted (with effect in accordance with Sch. 6 para. 12 of the amending Act) by Finance Act 2026 (c. 11), Sch. 6 paras. 7(3)(a)(ii), 12"
    },
    {
      "type": "F",
      "label": "F3",
      "text": "S. 192(1)(a) omitted (with effect in accordance with Sch. 6 para. 12 of the amending Act) by virtue of Finance Act 2026 (c. 11), Sch. 6 paras. 7(3)(b), 12"
    },
    {
      "type": "F",
      "label": "F4",
      "text": "S. 192(1)(b) substituted (with effect in accordance with Sch. 6 para. 12 of the amending Act) by Finance Act 2026 (c. 11), Sch. 6 paras. 7(3)(c), 12"
    },
    {
      "type": "F",
      "label": "F5",
      "text": "Word in s. 192(1)(c) substituted (with effect in accordance with Sch. 6 para. 12 of the amending Act) by Finance Act 2026 (c. 11), Sch. 6 paras. 7(3)(d), 12"
    },
    {
      "type": "F",
      "label": "F6",
      "text": "Words in s. 192(3) substituted (with effect in accordance with Sch. 6 para. 12 of the amending Act) by Finance Act 2026 (c. 11), Sch. 6 paras. 7(4), 12"
    },
    {
      "type": "F",
      "label": "F7",
      "text": "S. 192(6) omitted (with effect in accordance with Sch. 6 para. 12 of the amending Act) by virtue of Finance Act 2026 (c. 11), Sch. 6 paras. 7(5), 12"
    },
    {
      "type": "F",
      "label": "F8",
      "text": "Word in s. 192 heading substituted (with effect in accordance with Sch. 6 para. 12 of the amending Act) by Finance Act 2026 (c. 11), Sch. 6 paras. 7(2), 12"
    }
  ],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/ukpga/2010/8/section/192",
    "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."
}