Mark Middleditch (Allen & Overy) reviews recent developments affecting the City, including the consultation on interest expense and the corporation tax treatment of fines and related payments made by banks.
Restricting deductions for interest expense
For corporates generally the main elements of the BEPS related restrictions for interest expense proposed in the consultation paper (www.bit.ly/1kvUMKR) issued on 12 May by the Treasury and HMRC are now somewhat clearer (in particular the fixed ratio rule limiting net interest expense to 30% of UK EBITDA and the group ratio rule based on the net interest to EBITDA ratio for the worldwide group). However some significant questions remain for the banking and insurance sectors.
The consultation paper points out the obvious difficulty of operating the fixed ratio rule where groups are in a net interest income position....
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Mark Middleditch (Allen & Overy) reviews recent developments affecting the City, including the consultation on interest expense and the corporation tax treatment of fines and related payments made by banks.
Restricting deductions for interest expense
For corporates generally the main elements of the BEPS related restrictions for interest expense proposed in the consultation paper (www.bit.ly/1kvUMKR) issued on 12 May by the Treasury and HMRC are now somewhat clearer (in particular the fixed ratio rule limiting net interest expense to 30% of UK EBITDA and the group ratio rule based on the net interest to EBITDA ratio for the worldwide group). However some significant questions remain for the banking and insurance sectors.
The consultation paper points out the obvious difficulty of operating the fixed ratio rule where groups are in a net interest income position....
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)")