CFM96780 - Interest restriction: joint ventures: interest allowance (non-consolidated investment) election: example 1: opaque JV

Link to the structure diagram for this example

Here the same figures from the example at CFM96740 are used but consider that X plc has now made an investment allowance (non-consolidated investment) election. Note that qualifying net group-interest expense is referred to as QNGIE in the calculation.

Accounts X plc JV X plc Group
Operating profit 100 150 100
3rd party interest expenses - 50 - 60 - 50
Share of profits of JV - - 45
Profict Before Tax 50 90 95
  • X plc group share of profits from JV - 50%
Calculation of QNGIE X plc Group
QNGIE in X plc group ( pre-election) 50
Share of JV QNGIE 30
Total QNGIE - (A) 80
Calculation of group -EBITDA X plc Group
Group - EBITDA of X plc group ( pre-election) 145
Reduction in group - EBITDA - 45
Increase in share of group - EBITDA from JV group -EBITDA 75
Group - EBITDA - (B) 175
  • Group ratio with election - 46% - ( A/B)
Interest allowances X plc
Tax - EBITDA 100
X plc group ratio 46%
Interest allowance 46
Net tax- interest expense for X plc group 50
Less interest allowance - 46
Restriction 4

With the election X plc is now able to calculate a group ratio of 46%. If this is compared to the example in CFM96740 when the election has not been made, this is a significant increase and leads to a reduction in the interest restriction.