CFM90000 - Debt cap
Contents
The debt cap rules were introduced in Finance Act 2009 and apply to large groups with UK members with effect from a group’s first period of account that begins on or after 1 January 2010. The guidance for applying the debt cap rules is contained in the following chapters. The guidance will help HMRC staff and practitioners understand the legislation and how the rules apply to groups. The guidance will also provide assistance in risk assessing the potential impact of the rules to a group.
Overview |
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Which groups are affected |
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Group accounts |
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Gateway test |
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Financial services groups |
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Calculating the disallowance of financing expense amounts |
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Calculating the exemption of financing income amounts |
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Introduction to allocating the disallowance and exemption |
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Appointment of the authorised company |
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Statements of allocation |
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Failure to make statements of allocation |
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Intra-group short-term debt |
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Stranded reliefs |
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Available amount |
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Particular types of company |
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Anti-avoidance rules |
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Income from EEA group companies |
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Interaction with other rules |

