Finance Act 2026
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Change 1
62 Corporate interest restriction: capital expenditure and tax-EBITDA calculation
(1) In section 407 of TIOPA 2010 (amounts not brought into account in determining a company’s tax-EBITDA)— (a) in subsection (1)(b) (allowances or charges under CAA 2001), at the end insert “or capital expenditure for which a deduction is given under a relevant enactment”, and (b) after subsection (1) insert— (1A) For the purposes of subsection (1)(b) “relevant enactment” means— (a) section 86A of CTA 2009 (contributions to flood and coastal erosion risk management projects); (b) section 142 of CTA 2009 (waste disposal site preparation expenditure); (c) section 145 of CTA 2009 (waste disposal site restoration payments); (d) section 147 of CTA 2009 (cemeteries and crematoria). (2) The amendments made by this section have effect in relation to periods of account ending on or after 31 December 2021. (3) An interest restriction return which is revised to take account of the amendments made by this section is, despite paragraph 8(3) of Schedule 7A to TIOPA 2010, of effect if the revised return is received by an officer of Revenue and Customs before 1 October 2026.
62 Corporate interest restriction: capital expenditure and tax-EBITDA calculation
(1) In section 407 of TIOPA 2010 (amounts not brought into account in determining a company’s tax-EBITDA)— (a) in subsection (1)(b) (allowances or charges under CAA 2001), at the end insert “or capital expenditure for which a deduction is given under a relevant enactment”, and (b) after subsection (1) insert— (1A) For the purposes of subsection (1)(b) “relevant enactment” means— (a) section 86A of CTA 2009 (contributions to flood and coastal erosion risk management projects); (b) section 142 of CTA 2009 (waste disposal site preparation expenditure); (c) section 145 of CTA 2009 (waste disposal site restoration payments); (d) section 147 of CTA 2009 (cemeteries and crematoria). (2) The amendments made by this section have effect in relation to periods of account ending on or after 31 December 2021. (3) An interest restriction return which is revised to take account of the amendments made by this section is, despite paragraph 8(3) of Schedule 7A to TIOPA 2010, of effect if the revised return is received by an officer of Revenue and Customs before 1 October 2026.
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