Part F
Recharacterisation of certain transactions
Interest apportionment on thin capitalisation:
Debt percentage of worldwide group
FE 17Consolidation of debts and assets
For an excess debt entity that is a company, the debt percentage of a worldwide group is calculated under generally accepted accounting practice for the consolidation of companies for the purposes of eliminating intra-group balances by consolidating the debts and assets of the members of the entity’s worldwide group using—
- a financial standard used in the country in which the entity’s ultimate non-resident parent company resides, as described in section FE 18(1)(a), if applicable; or
- generally accepted accounting practice.
Compare
- 2004 No 35 s FG 5(2), (10)