Paul Fay Director in Horwath Clark Whitehill's London Corporate Tax Group comments on the new UK domestic thin capitalisation regime
This article focuses on the new UK domestic thin capitalisation regime in light of the Finance Bill and Revenue guidance notes.
Thin capitalisation is broadly where a group relationship enables a company to take on higher levels of borrowings than a third-party lender would advance. A group may look to introduce excess debt for a number of reasons. For example a non-UK parent may wish to extract profits tax-efficiently or may look to increase UK interest costs to shelter taxable profits.
The UK's previous transfer pricing regime which applied up to 31 March 2004 effectively required cross-border group transactions to be taxed...
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Paul Fay Director in Horwath Clark Whitehill's London Corporate Tax Group comments on the new UK domestic thin capitalisation regime
This article focuses on the new UK domestic thin capitalisation regime in light of the Finance Bill and Revenue guidance notes.
Thin capitalisation is broadly where a group relationship enables a company to take on higher levels of borrowings than a third-party lender would advance. A group may look to introduce excess debt for a number of reasons. For example a non-UK parent may wish to extract profits tax-efficiently or may look to increase UK interest costs to shelter taxable profits.
The UK's previous transfer pricing regime which applied up to 31 March 2004 effectively required cross-border group transactions to be taxed...
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:
