Section 28

INTRODUCTORY

1  Part 10 of TIOPA 2010 (corporate interest restriction) is amended as follows.

TAX-INTEREST AMOUNTS: AMOUNTS CAPITALISED IN INTANGIBLE FIXED ASSETS

2  In Chapter 3 (tax-interest amounts), after section 391 insert–

391A  

“Amounts capitalised in carrying value of intangible fixed assets

391A  In determining for the purposes of this Part whether an amount is a tax-interest expense amount or tax-interest income amount, section 906(1) of CTA 2009 (priority of intangible fixed asset rules) does not apply in respect of any matter which may be brought into account in accordance with Part 5 or 7 of that Act.”

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