The public benefit infrastructure exemption

The draft Finance Bill provisions on the restriction on deductibility of corporate interest expense do not contain any provisions dealing with a public benefit infrastructure exemption (PBIE): the remaining drafting is promised by the end of January. However, the supporting document providing responses to the consultation provides some enlightening detail on a new proposal to introduce a wider exemption than was first contemplated. In particular, it appears that an exemption for rental properties is now contemplated, as well as some limited grandfathering for intra-group debt borrowed by certain types of project finance company.