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HMRC internal manual

Corporate Finance Manual

Debt cap: statement of allocation: groups with dual resident investing companies

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

Allocation of disallowance to a dual resident investing company {#}

If a group includes a dual resident investing company (DRIC) then TIOPA10/S280A applies. This section requires that, where a group includes a DRIC, the statement of allocation must include all relevant group companies that are not DRICs and that it specifies all of the financing expense amounts of those relevant group companies.

This requirement means that the statement allocates the disallowance first to the financing expense amounts of all non-DRIC relevant group companies before any disallowance is allocated to a DRIC included in the statement.

Meaning of Dual Resident Investing Company

A company is a DRIC if, for part or all of the period of account of the worldwide group to which the statement applies, the company is prevented by CTA10/S109 (2) from surrendering losses as group relief.