Limitations on deductibility of corporate interest expense: where are we now?

The corporate interest restriction is the latest addition to the list of potential limitations on the deductibility of corporate interest expense, following the introduction of the hybrid mismatch regime. The possible impact of the rules should be considered for any UK companies and groups claiming or modelling deductions in respect of interest costs, whether in the context of financing arrangements, mergers and acquisitions, joint ventures, or restructurings. However, notwithstanding these new regimes, the UK remains a comparatively attractive holding company jurisdiction.