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Tax and the City briefing for November 2015

Mark Middleditch (Allen & Overy) reports the latest tax developments that matter, including a consultation on a fixed ratio rule; patent box reform; country by country reporting; and the special corporation tax rate applying to payments of restitution interest made by HMRC.
 

Consultation on a fixed ratio rule 

On 22 October the government issued a consultation paper on limiting interest deductions (www.bit.ly/1kvUMKR). This is in response to BEPS Action 4 on preventing base erosion through excessive interest. Although the government acknowledges that a statutory response is justified to the problems highlighted by Action 4 the precise scope of any new regime remains uncertain. If it included for example an appropriate threshold or was limited to multinational groups its impact could be much less extensive.

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