Taxation (International and Other Provisions) Act 2010 section 325

Stranded management expenses in non-trading loan relationships: financing income

Section 325 dealt with the treatment of stranded management expenses arising from non-trading loan relationships as financing income under the worldwide debt cap rules, but has been repealed following the introduction of the corporate interest restriction regime.

• Section 325 was part of the worldwide debt cap provisions in Part 7 of the Taxation (International and Other Provisions) Act 2010, which limited the amount of financing expense UK companies could deduct.
• The section specifically addressed how management expenses that became "stranded" (i.e. unable to be relieved) in connection with non-trading loan relationships should be classified as financing income.
• The entire Part 7 worldwide debt cap regime, including section 325, was repealed by Finance (No. 2) Act 2017 and replaced by the corporate interest restriction rules.
• The repeal takes effect for periods of account of worldwide groups beginning on or after 1 April 2017, meaning the old rules may still be relevant for earlier periods.