Part 7Tax treatment of financing costs and income

CHAPTER 9“Available amount”

332The available amount

1

References in this Part to the “available amount” for a period of account of the worldwide group are to the sum of the amounts disclosed in the financial statements of the group for that period in respect of—

a

interest payable on amounts borrowed,

b

amortisation of discounts relating to amounts borrowed,

c

amortisation of premiums relating to amounts borrowed,

d

amortisation of ancillary costs relating to amounts borrowed,

e

the financing cost implicit in payments made under finance leases,

f

the financing cost relating to debt factoring, or

g

matters of such other description as may be specified in regulations made by the Commissioners.

2

An amount that falls within any of paragraphs (a) to (g) of subsection (1) is to be disregarded for the purposes of that subsection to the extent that—

a

the amount represents a dividend payable in respect of preference shares, and

b

those shares are recognised as a liability in the financial statements of the group for the period.