Martin Rybak, a Senior Consultant, and Jo Myers, a Director, on Ernst & Young's Transfer Pricing team within International Tax Services, assess the impact of HMRC's PBR changes to UK interest relief rules
Martin Rybak a Senior Consultant and Jo Myers a Director on Ernst & Young's Transfer Pricing team within International Tax Services assess the impact of HMRC's PBR changes to UK interest relief rules
The Pre-Budget Report included two proposed major changes to the UK's rules on interest relief namely: (1) the introduction of a 'worldwide debt cap' and (2) the proposed strengthening of the 'unallowable purpose test' in FA 1996 Sch 9 para 13.
This was followed by the publication of draft legislation covering both proposed changes on 9 December....
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Martin Rybak, a Senior Consultant, and Jo Myers, a Director, on Ernst & Young's Transfer Pricing team within International Tax Services, assess the impact of HMRC's PBR changes to UK interest relief rules
Martin Rybak a Senior Consultant and Jo Myers a Director on Ernst & Young's Transfer Pricing team within International Tax Services assess the impact of HMRC's PBR changes to UK interest relief rules
The Pre-Budget Report included two proposed major changes to the UK's rules on interest relief namely: (1) the introduction of a 'worldwide debt cap' and (2) the proposed strengthening of the 'unallowable purpose test' in FA 1996 Sch 9 para 13.
This was followed by the publication of draft legislation covering both proposed changes on 9 December....
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
