Commentary on Sections Overview
534.This Part rewrites Schedule 15 to FA 2009, the rules on debt capping.
535.The Part provides for the restriction of the tax deduction for finance expenses of group companies. The aggregate tax deduction for United Kingdom group members is limited to the consolidated gross finance expense of the group.
536.The restricted net expense is then allocated to one or more group companies. If other group members have net finance income from the group that finance income may be reduced in computing their profits.