Section 390 The worldwide group's aggregate net tax-interest expense and incomeF1

(1)

The “aggregate net tax-interest expense” of a worldwide group for a period of account of the group is (subject to subsection (2))—

(a)

the total of the net tax-interest expense for the period of each relevant company that has such an amount, less

(b)

the total of the net tax-interest income for the period of each relevant company that has such an amount.

(2)

Where the amount determined under subsection (1) is negative, the “aggregate net tax-interest expense” of the group for the period is nil.

(3)

The “aggregate net tax-interest income” of a worldwide group for a period of account of the group is (subject to subsection (4))—

(a)

the total of the net tax-interest income for the period of each relevant company that has such an amount, less

(b)

the total of the net tax-interest expense for the period of each relevant company that has such an amount.

(4)

Where the amount determined under subsection (3) is negative, the “aggregate net tax-interest income” of the group for the period is nil.

(5)

In this section “relevant company” means a company that was a member of the group at any time during the period of account of the group.

(6)

This section applies for the purposes of this Part.

Annotations

F1: Pt. 10: the existing Pt. 10 renumbered as Pt. 11 (except for ss. 375, 376 which are repealed), the existing ss. 372-374, 377-382 renumbered as ss. 499-507 and a new Pt. 10 (ss. 372-498) inserted (with effect in accordance with Sch. 5 para. 25(1)-(3) of the amending Act) by Finance (No. 2) Act 2017 (c. 32), Sch. 5 para. 1, 10(1)(2)(a)(3) (with Sch. 5 paras. 27, 32-34)

C1: Pt. 10 excluded by 2010 c. 4, s. 937NA (as 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. 7)
C2: Pt. 10 excluded by 2010 c. 4, s. 938V(d) (as substituted (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. 9)
C3: Pt. 10 excluded by 2010 c. 4, s. 938N(e) (as substituted (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. 8)