The Taxation (International and Other Provisions) Act 2010 (Part 7) (Amendment) Regulations 2012
Part 7 of the Taxation (International and Other Provisions) Act 2010 (c.8) (“TIOPA”) deals with the tax treatment of financing costs and income of companies which are members of a worldwide group. Chapter 4 deals with exemption of financing income amounts. The new section 314A TIOPA includes a Controlled Foreign Company (“CFC”) charge as a financing income amount for all debt cap purposes. Section 293 TIOPA exempts a financing income amount for the purposes of corporation tax. However, the CFC charge is not within the charge to corporation tax. Therefore it cannot be made exempt from corporation tax by virtue of section 293 TIOPA in the way that other financing income amounts of a company are exempted.