Interaction of controlled foreign companies regime and worldwide debt cap
HM Treasury has published draft regulations amending the CFC and debt cap rules to ensure that the two regimes interact correctly.
‘The regulations [The Taxation (International and Other Provisions) Act 2010 (Part 7) (Amendment) Regulations 2013] ensure that the debt cap mechanisms for reducing or eliminating a corporation tax charge can also be applied, in appropriate circumstances, to a CFC charge. They do this by making sure that a CFC charge can be included as part of the allocated amount within the debt cap rules,’ the Treasury said.
Interaction of controlled foreign companies regime and worldwide debt cap
HM Treasury has published draft regulations amending the CFC and debt cap rules to ensure that the two regimes interact correctly.
‘The regulations [The Taxation (International and Other Provisions) Act 2010 (Part 7) (Amendment) Regulations 2013] ensure that the debt cap mechanisms for reducing or eliminating a corporation tax charge can also be applied, in appropriate circumstances, to a CFC charge. They do this by making sure that a CFC charge can be included as part of the allocated amount within the debt cap rules,’ the Treasury said.
