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HMRC internal manual

Corporate Finance Manual

From
HM Revenue & Customs
Updated
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Debt cap: overview: scope of the guidance

What this guidance is intended to do

This guidance explains how the legislation within TIOPA10/PT7 (Tax Treatment of Financing Costs and Income) is applied to large groups of companies where at least one of the group members is either a company resident in the UK for corporation tax purposes, or has a permanent establishment carrying on a trade in the UK. This legislation and related secondary legislation are referred to as the ‘debt cap’ rules.

The guidance is broken down into chapters, each dealing with different parts of the debt cap rules. It will enable you to

  • tell which groups are affected
  • work out what is a group for the purposes of the debt cap measure
  • calculate disallowances and exemptions
  • understand how groups are to account for disallowance and exemptions
  • deal with claims to exclude particular amounts from the debt cap rules, and
  • risk assess groups.