Anton Hume and Andrew Stewart (BDO) consider a concerning aspect of the new interest restriction that will come into effect on 1 April 2017.
Following the OECD’s recommendations on Action Point 4 of its BEPS programme the UK government announced it would be implementing a new interest limitation in line with the recommendations from 1 April 2017.
Two consultations later draft rules have been included in the Finance Bill 2017 and broadly follow expectations.
This article focuses on one specific aspect of the new rules which arises from the combination of limits designed to replace the need for a separate worldwide debt cap. Unlike other areas of discussion in respect of the rules this aspect has not changed at all since the second consultation and although HMRC’s reply to the consultation acknowledges that this area has been questioned it is completely silent on whether the...
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Anton Hume and Andrew Stewart (BDO) consider a concerning aspect of the new interest restriction that will come into effect on 1 April 2017.
Following the OECD’s recommendations on Action Point 4 of its BEPS programme the UK government announced it would be implementing a new interest limitation in line with the recommendations from 1 April 2017.
Two consultations later draft rules have been included in the Finance Bill 2017 and broadly follow expectations.
This article focuses on one specific aspect of the new rules which arises from the combination of limits designed to replace the need for a separate worldwide debt cap. Unlike other areas of discussion in respect of the rules this aspect has not changed at all since the second consultation and although HMRC’s reply to the consultation acknowledges that this area has been questioned it is completely silent on whether the...
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:
