Mark Joscelyne and Hugo Webb of Olswang LLP discuss the worldwide debt cap in FA 2009 Sch 15
For some years the UK Government has been concerned that international groups have burdened their UK companies with excessive amounts of debt so as to take advantage of the UK's relatively generous interest deduction rules. In order to combat this perceived abuse and as a 'quid pro quo' for the foreign dividend exemption rules introduced in FA 2009 the 'worldwide debt cap' (WDC) rules were (after a lengthy consultation process and several iterations) introduced by FA 2009 s 35 and Sch 15 (references to Parts and paras below are (unless stated otherwise) to Sch 15).
In essence the purpose of the WDC is to...
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:
Mark Joscelyne and Hugo Webb of Olswang LLP discuss the worldwide debt cap in FA 2009 Sch 15
For some years the UK Government has been concerned that international groups have burdened their UK companies with excessive amounts of debt so as to take advantage of the UK's relatively generous interest deduction rules. In order to combat this perceived abuse and as a 'quid pro quo' for the foreign dividend exemption rules introduced in FA 2009 the 'worldwide debt cap' (WDC) rules were (after a lengthy consultation process and several iterations) introduced by FA 2009 s 35 and Sch 15 (references to Parts and paras below are (unless stated otherwise) to Sch 15).
In essence the purpose of the WDC is to...
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:
