Introduction Details of the Schedule Part 1 - Overview
5.Schedule 15 is divided into eleven parts. Part 1 provides an overview of the Schedule. Part 2 sets out the circumstances in which the Schedule applies to a worldwide group of companies for any particular period of account. Part 3 provides the basic rules where an amount of financing expense of UK group companies falls to be disallowed. Part 4 provides for certain financing income of UK group companies to be exempted from corporation tax but only to the extent that financing expense has been disallowed under Part 3. Part 5 allows certain intra-group financing income to be exempted from corporation tax where the paying company is resident in the European Economic Area (EEA) unless the paying company is resident in the UK and, the effect of Part 3 aside, is denied a deduction for the payment for tax purposes. Part 6 provides for anti-avoidance measures to counter the effect of schemes designed to avoid provisions of the Schedule. Part 7 and Part 8 define the amounts and types of intra-group financing income and financing expense that are used in Part 3 to calculate any disallowance, and are used in Part 4 to determine the amount of financing income to be disregarded. Part 9 sets out how the external gross finance expense of the worldwide group is to be computed for the purposes of the Schedule. Part 10 contains further definitions and other interpretative provisions. Part 11 deals with commencement and consequential amendments to other legislation.