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

What this guidance is intended to do

This guidance explains how the legislation within TIOPA10/PT7 (Tax Treatment of Financing Costs and Income) is applied to large groups of companies where at least one of the group members is either a company resident in the UK for corporation tax purposes, or has a permanent establishment carrying on a trade in the UK. This legislation and related secondary legislation are referred to as the ‘debt cap� rules.

»Ê¹ÚÌåÓýapp debt cap was repealed by Finance (No.2) Act 2017 with effect from 1 April 2017 when it was superseded by the Corporate Interest Restriction. Draft guidance is available at:

/government/publications/corporate-interest-restriction-draft-guidance

Special rules apply where the period of account straddling 1 April 2017. See CFM93060 of the draft guidance for further details.

»Ê¹ÚÌåÓýapp guidance is broken down into chapters, each dealing with different parts of the debt cap rules. It will enable you to

• tell which groups are affected
• work out what is a group for the purposes of the debt cap measure
• calculate disallowances and exemptions
• understand how groups are to account for disallowance and exemptions
• deal with claims to exclude particular amounts from the debt cap rules, and
• risk assess groups.