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HMRC internal manual

Corporate Finance Manual

Debt cap: statement of allocation: required information for disallowance

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

The information to be provided in the statement of allocated disallowance

There are statutory requirements for the information to be provided in a statement of allocated disallowances (TIOPA10/S280). The following should be included on the statement of disallowance:

  • the tested expense amount;
  • the available amount;
  • the total disallowed amount;
  • a list of all the companies to which TIOPA10/CH3 applies;
  • in relation to each listed company, the financing expense amounts to be disallowed for the relevant period of account; and
  • the relevant details in relation to each amount.

But see CFM91625 if a group includes a dual resident investing company.

The relevant details in relation to each financing expense amount are

  • which of the conditions in TIOPA10/S313 is met in relation to that amount and
  • the relevant accounting period of the company in which (apart from the disallowance) the amount would be brought into account.

There is further information on S313 at CFM91000 onwards.

The sum of the financing expenses disallowed in the statement must equal the total disallowed amount.