Mark Baldwin Tax Partner Macfarlanes discusses the recent announcement from the Inland Revenue which will have a significant impact on private equity debt
On 4 March the Inland Revenue announced two changes to be introduced in this year's Finance Bill which will have a significant impact on the tax relief available to many companies in which private equity funds invest for their financing costs.
The first change is to the transfer pricing rules in Schedule 28AA to the Income and Corporation Taxes Act 1988. Broadly these rules apply where provision is made between two entities and there is a prescribed control relationship (typically those found in corporate groups and evenly balanced joint ventures) between them. Where such a relationship subsists the UK tax effects of transactions...
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Mark Baldwin Tax Partner Macfarlanes discusses the recent announcement from the Inland Revenue which will have a significant impact on private equity debt
On 4 March the Inland Revenue announced two changes to be introduced in this year's Finance Bill which will have a significant impact on the tax relief available to many companies in which private equity funds invest for their financing costs.
The first change is to the transfer pricing rules in Schedule 28AA to the Income and Corporation Taxes Act 1988. Broadly these rules apply where provision is made between two entities and there is a prescribed control relationship (typically those found in corporate groups and evenly balanced joint ventures) between them. Where such a relationship subsists the UK tax effects of transactions...
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:
