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

Condition C - no qualifying EEA tax relief

Qualifying EEA tax relief is a deduction or other form of relief that the paying company would receive for the payment of an amount that is a financing income amount in the hands of the recipient.

»Ê¹ÚÌåÓýapp financing income amount will not be brought into account for the purposes of corporation tax if, along with the other conditions, condition C in TIOPA10/S263 is met. Qualifying EEA tax relief for the payment must not be available to the payer either in the current period, a previous period (CFM92900), or a future period.

If relief can be obtained in any period, whether it is or not, condition C is not met and the recipient has to bring the financing income amount into account for the purposes of corporation tax.