The Tax Treatment of Financing Costs and Income (Correction of Mismatches: Partnerships and Pensions) Regulations, SI 2012/3111, insert new sections 332D and 332E into the debt cap provisions of TIOPA 2010 in relation to loans from a partnership, finance leasing and debt factoring. The debt cap sets a ceiling on interest and other financing expenses for which corporation tax deductions are available to UK members of a worldwide group of companies.
‘The regulations were subject to a four week consultation in autumn 2012. The consultation was short because of the limited number of interested parties and the existence of the Debt Cap Working Group who were particularly invited to comment,’ HMRC said.
The Tax Treatment of Financing Costs and Income (Correction of Mismatches: Partnerships and Pensions) Regulations, SI 2012/3111, insert new sections 332D and 332E into the debt cap provisions of TIOPA 2010 in relation to loans from a partnership, finance leasing and debt factoring. The debt cap sets a ceiling on interest and other financing expenses for which corporation tax deductions are available to UK members of a worldwide group of companies.
‘The regulations were subject to a four week consultation in autumn 2012. The consultation was short because of the limited number of interested parties and the existence of the Debt Cap Working Group who were particularly invited to comment,’ HMRC said.
