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HMRC internal manual

Corporate Finance Manual

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HM Revenue & Customs
Updated
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Debt cap: statement of allocation: outline for exemption statements

The statement of allocated exemptions

TIOPA10/S290 to S293 provide for the submission of, and information to be provided on, the statement of allocated exemptions. The statement of allocated exemptions is the means by which financing income of the UK group companies is exempted. The effect of the statement is that the financing income amounts of UK group companies that are specified in the statement are not brought into account by the UK group company for the purposes of corporation tax.

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

The statement of allocated exemptions must comply with the requirements specified by TIOPA10/S292. The statement must be signed by the appropriate person for each of the UK group companies or, if an authorised company has been appointed (CFM91400), the appropriate person of the authorised company. For guidance on the meaning of appropriate person see CFM91350.