Taxes Consolidation Act 1997 section 835AAJ

Election

Section 835AAJ sets out the rules governing elections to use the group ratio or equity ratio methods for the purposes of the interest limitation rule.

  • An election to use the group ratio (section 835AAH) or the equity ratio (section 835AAI) must be made on the Revenue-prescribed form on or before the specified return date for the relevant accounting period.
  • A relevant entity cannot elect for both the group ratio and the equity ratio in respect of the same accounting period.
  • An interest group whose members include a company that is not a member of a worldwide group cannot make an election under either ratio.
  • The election must be made on the Form CT1.

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