Your World of Legal Intelligence
 United Kingdom | +44 (0) 20 7284 8080

Chapter CFM91020

Document Cited in Related
Vincent
Published date16 April 2016
Record NumberCFM91020
CourtHM Revenue & Customs
IssuerHM Revenue & Customs

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

What is the tested expense amount?

The tested expense amount is built up in a number of stages.

First, it is necessary to identify all of the relevant group companies - see CFM91060 for the definition of a relevant group company.

Second, the financing expense amounts and financing income amounts must be determined. Guidance on establishing the company’s financing expense amounts is at CFM91030. For further information on establishing the company’s financing income amounts see CFM91230.

This enables you to determine the company’s net financing deduction, which is defined in TIOPA10/S329. It is simply the sum of the relevant group company’s financing expense amounts for the period less the sum of the company’s financing income amounts for the period.

Where, for a company, the difference between these two sums is negative (i.e. the company’s financing income exceeds its financing expenses), the net financing deduction of the company for the period is nil. Similarly where the difference is small the net financing deduction of the company for the period is nil.

To establish whether or not the difference is small, see CFM91080.

The final step is to aggregate the net financing...

To continue reading

Request your trial

VLEX uses login cookies to provide you with a better browsing experience. If you click on 'Accept' or continue browsing this site we consider that you accept our cookie policy. ACCEPT