Martin Rybak a Senior Consultant and Jo Myers a Director on Ernst & Young's Transfer Pricing team within International Tax Services assess the impact of HMRC's PBR changes to UK interest relief rules
The Pre-Budget Report included two proposed major changes to the UK's rules on interest relief namely: (1) the introduction of a 'worldwide debt cap' and (2) the proposed strengthening of the 'unallowable purpose test' in FA 1996 Sch 9 para 13.
This was followed by the publication of draft legislation covering both proposed changes on 9 December. In publishing the draft legislation HM Treasury (HMT) has stressed that the legislation has been released at an early stage to enable business and government fully to consult about its...
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Martin Rybak a Senior Consultant and Jo Myers a Director on Ernst & Young's Transfer Pricing team within International Tax Services assess the impact of HMRC's PBR changes to UK interest relief rules
The Pre-Budget Report included two proposed major changes to the UK's rules on interest relief namely: (1) the introduction of a 'worldwide debt cap' and (2) the proposed strengthening of the 'unallowable purpose test' in FA 1996 Sch 9 para 13.
This was followed by the publication of draft legislation covering both proposed changes on 9 December. In publishing the draft legislation HM Treasury (HMT) has stressed that the legislation has been released at an early stage to enable business and government fully to consult about its...
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:
.jpg?sfvrsn=335a554c_0 "300 x 250 (MPU)")