»Ê¹ÚÌåÓýapp

TIOPA10/S440-S442

While a company is a qualifying infrastructure company (QIC), as well as exempting certain amounts from the company’s tax-interest expense, further adjustments are made in the calculation of any potential Corporate Interest Restriction.

• »Ê¹ÚÌåÓýapp QIC will be treated in that same accounting period as having nil tax-interest income (TIOPA10/S440).
• Amounts that are taken out of tax-interest expense (under s438) or tax-interest income (under s440) are left out of for the purposes of calculating the adjusted net group-interest expense and qualifying net group-interest expense for the period of account concerned (TIOPA10/S442(2)).
• »Ê¹ÚÌåÓýapp QIC will be treated as having nil tax-EBITDA (TIOPA10/S441).
• »Ê¹ÚÌåÓýapp QIC is treated as if it was not part of the group for the relevant account period when calculating group-EBITDA (TIOPA10/S442(3)).

Note that amounts of tax-interest income, tax-EBITDA and group-EBITDA are treated as nil regardless of whether any amounts are excluded from tax-interest expense.

Where a worldwide group includes a QIC ordinarily the de-minimis provisions are disapplied, but this is subject to an exception.

Effect of transitional period and one fails all fails provisions

»Ê¹ÚÌåÓýapp amounts exempted or treated as nil will be altered in respect of a QIC in an accounting period subject to the transitional rules, or a joint election in which one of the members has failed the conditions necessary to be a qualifying infrastructure companies.