The Tax Treatment of Financing Costs and Income (Correction of Mismatches) Regulations 2010
Part 7 of the Taxation (International and Other Provisions) Act 2010 (“TIOPA 2010”) applies to groups of companies. It provides for the disallowance for corporation tax purposes of net financing deductions of the UK members of a group to the extent that the total of those deductions exceeds the “available amount.” The available amount is the sum of the amounts disclosed in the financial statements of the worldwide group for the relevant period of account in respect of matters specified in section 332(1) of TIOPA 2010 or in regulations made under that section.