# Taxation (International and Other Provisions) Act 2010, Section 399: The group ratio percentage


(1) For the purposes of this Part “the group ratio percentage” of a worldwide group for a period of account of the group is (subject to subsection (2)) the following proportion expressed as a percentage—
A Bwhere—
A is the qualifying net group-interest expense of the group for the period;
B is the group-EBITDA of the group for the period.
(2) “The group ratio percentage” is 100% where—
(a) the percentage determined under subsection (1) is negative or higher than 100%, or
(b) B in that subsection is zero.
(3) See—
section 414 for the meaning of “qualifying net group-interest expense”;
section 416 for the meaning of “group-EBITDA”.

---
Source: https://www.legislation.gov.uk/ukpga/2010/8/section/399 (the official version)
Page: https://openlegislation.uk/taxation-international-and-other-provisions-act-2010/section-399
Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives.