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HMRC internal manual

Corporate Finance Manual

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HM Revenue & Customs
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Debt cap: calculating the exemption of financing income amounts: tested income amount

What is the tested income amount?

The tested income amount for the period of account of a worldwide group is defined in TIOPA10/S330(1) as the sum of the net financing income for each UK group company.

The net financing income is also defined in section 330, and it simply is the sum of each of the relevant group company’s financing income amounts for the period less the sum of the company’s financing expense amounts for the period.

Where, for a UK group company, the difference between these two sums is negative (i.e. the relevant company’s financing expense exceeds its financing income) then the net financing income of the company for the period is nil. Similarly where the difference is small the net financing deduction of the company for the period is nil.

For further information on establishing the company’s financing expense amounts see CFM91030.

For further information on establishing the company’s financing income amounts see CFM91230.

To establish whether or not the difference is small, see CFM91240.