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HMRC internal manual

Corporate Finance Manual

Debt cap: gateway test: de minimis limit

This guidance applies to worldwide group periods of account ending before or straddling 1 April 2017.

Where the net debt amount for a relevant group company is less than £3 million then the net debt amount is deemed to be nil

TIOPA10/S262 (3) deems the net debt amount of a relevant group company to be nil, if the calculated amount is less than £3 million. This means that relevant group or group securitisation companies with small amounts of average net debt can be excluded from the gateway test.