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HMRC internal manual

Corporate Finance Manual

Debt cap: statement of allocation: outline for disallowance statements

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

The statement of allocated disallowances

TIOPA10/S278 to S282 provide for the submission of, and information to be included on, the statement of allocated disallowances. The statement of allocated disallowances is the means by which the total disallowed amount is allocated between the relevant group companies. The effect of the statement is that the financing expense amounts of relevant group companies that are specified in the statement are not brought into account by the relevant group company for the purposes of corporation tax.

It is the responsibility of the reporting body (see CFM91330) to make the statement of allocated disallowance. The statement must be submitted by the reporting body within twelve months of the end of the relevant period of account i.e. the period of account of the worldwide group.

The statement of allocated disallowance must comply with the requirements specified in TIOPA10/S280 (CFM91620). The statement must be signed by the appropriate person for each of the relevant group companies or, if an authorised company has been appointed (CFM91400), the appropriate person of the authorised company. For guidance on the meaning of the appropriate person see CFM91350.