Jonathan Rosen (Akin Gump Strauss Hauer & Feld) considers the recent restrictions on corporate interest deductibility, and their impact on the UK’s attractiveness as a holding company jurisdiction.
The corporate interest restriction (CIR) which followed hot on the heels of the hybrid mismatch regime has introduced a significant new limitation on the deductibility of corporate interest expense. The CIR and hybrid mismatch regimes are the latest significant limitations on corporate interest expense deductibility which can be added to the existing list. Now that the CIR has been in place for some months this is a good time to take stock of the various restrictions on corporate interest deductibility and the impact of these changes in the context of the UK’s attractiveness as a holding company jurisdiction.
Corporate interest restriction
The CIR was finally enacted in F(No.2)A 2017 following a long period of...
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Jonathan Rosen (Akin Gump Strauss Hauer & Feld) considers the recent restrictions on corporate interest deductibility, and their impact on the UK’s attractiveness as a holding company jurisdiction.
The corporate interest restriction (CIR) which followed hot on the heels of the hybrid mismatch regime has introduced a significant new limitation on the deductibility of corporate interest expense. The CIR and hybrid mismatch regimes are the latest significant limitations on corporate interest expense deductibility which can be added to the existing list. Now that the CIR has been in place for some months this is a good time to take stock of the various restrictions on corporate interest deductibility and the impact of these changes in the context of the UK’s attractiveness as a holding company jurisdiction.
Corporate interest restriction
The CIR was finally enacted in F(No.2)A 2017 following a long period of...
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:
