Part 7Tax treatment of financing costs and income

CHAPTER 8“Tested expense amount” and “tested income amount”

330The tested income amount

1

References in this Part to the “tested income amount” for a period of account of the worldwide group are to the sum of the net financing incomes of each UK group company.

2

The reference in subsection (1) to the “net financing income” of a company for a period of account of the worldwide group is to—

a

the sum of the company's financing income amounts for the period (see section 314), less

b

the sum of the company's financing expense amounts for the period (see section 313).

3

References in subsection (2) to a company's financing expense amounts or financing income amounts for a period of account of the worldwide group do not include any amount that arises as a result of a transaction that takes place at a time at which the company is not a UK group company.

4

If the amount determined in accordance with subsection (2) is negative, the net financing income of the company for the period is nil.

5

If the amount determined in accordance with subsection (2) is small (see section 331), the net financing income of the company for the period is nil.