Taxation (International and Other Provisions) Act 2010 section 337

The worldwide group

Section 337 defined the concept of the "worldwide group" for the purposes of the worldwide debt cap rules in Part 7 of TIOPA 2010, but this provision has been repealed and replaced by the corporate interest restriction regime.

• Section 337 was part of the worldwide debt cap rules contained in Part 7 of TIOPA 2010, which limited the amount of tax-deductible financing costs for UK members of large multinational groups.
• The section defined what constituted a "worldwide group" for the purposes of applying those debt cap provisions.
• Part 7 of TIOPA 2010, including section 337, was repealed by Finance (No. 2) Act 2017 and replaced by the corporate interest restriction rules introduced by section 20 and Schedule 5 of that Act.
• The repeal takes effect for periods of account of worldwide groups beginning on or after 1 April 2017, meaning the old worldwide debt cap rules can still apply to earlier periods.