Taxation (International and Other Provisions) Act 2010 Schedule 7A paragraph 1

Appointment by a worldwide group of a reporting company

Schedule 7A paragraph 1 sets out how a worldwide group appoints one of its members as the reporting company responsible for dealing with HMRC on behalf of the group in relation to the corporate interest restriction rules.

  • Any member of a worldwide group can appoint an eligible company as the group's reporting company by giving notice to HMRC, specifying the first period of account for which the appointment applies
  • The notice must be given within 12 months of the end of that first period of account and must be authorised by at least 50% of the group's eligible companies
  • A company is eligible if it was a UK group company at some point during the specified period of account and was not dormant throughout that period
  • Once made, the appointment applies to the specified period and all subsequent periods of account, and companies that authorised the notice may opt out of being treated as consenting companies for the reporting company's returns

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