A detailed guide to the key anti-avoidance rules, by LexisNexis®PSL Tax, with additional practitioner comment from Adam Blakemore and Catherine Richardson of Cadwalader, Wickersham & Taft and Kitty Swanson and Matthew Mortimer of Mayer Brown.
There are a number of anti-avoidance rules that may apply to restrict the tax deductibility of loan interest for a corporate borrower within the charge to UK corporation tax. They are:
the loan relationships regime anti-avoidance rule (RAAR);
the unallowable purposes rule;
the rules recharacterising interest as a distribution;
the corporate interest restriction;
the transfer pricing rules;
the hybrid and other mismatches rules;
non-market loans; and
the general anti-abuse rule.
For this purpose...
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:
A detailed guide to the key anti-avoidance rules, by LexisNexis®PSL Tax, with additional practitioner comment from Adam Blakemore and Catherine Richardson of Cadwalader, Wickersham & Taft and Kitty Swanson and Matthew Mortimer of Mayer Brown.
There are a number of anti-avoidance rules that may apply to restrict the tax deductibility of loan interest for a corporate borrower within the charge to UK corporation tax. They are:
the loan relationships regime anti-avoidance rule (RAAR);
the unallowable purposes rule;
the rules recharacterising interest as a distribution;
the corporate interest restriction;
the transfer pricing rules;
the hybrid and other mismatches rules;
non-market loans; and
the general anti-abuse rule.
For this purpose...
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:
