The de minimis mismatch, how to identify the group and relevant companies, clearing intercompany loans ... Robert Langston looks at five key issues that arise in practice concerning the debt cap rules
This article outlines five practical issues (and basic planning opportunities) which arise from the worldwide debt cap.
Many other practical issues may arise in addition to those covered here; for example where there are non-co-terminous accounting periods different currencies used within a group and hybrid entities.
Some of these issues (including the de minimis mismatch covered in this article) are identified in the HMRC Technical Note proposing changes to the debt cap (available at www.lexisurl.com/5HIfI).
This highlights a final issue with the debt cap...
