Taxes Consolidation Act 1997 section 835AAO

Order of application

Section 835AAO establishes the priority of the interest limitation rules relative to other tax provisions.

• The interest limitation rules in this Part apply after all other provisions of the Tax Acts and the Capital Gains Tax Acts have been applied.
• The only exception is section 811C, the general anti-avoidance provision, which takes precedence over the interest limitation rules.
• Section 811C replaced the former general anti-avoidance provision (section 811) for transactions carried out on or after 23 October 2014.
• This ordering ensures that the interest limitation is calculated on the basis of taxable amounts already determined under all other relevant tax rules.