Anneli Collins Head of International & Finance Tax and Michelle Quest Private Equity tax partner KPMG report on the impact of the transfer pricing changes in the Finance Bill for corporate and PE deals
On 4 March the Revenue announced transfer pricing changes which will have a significant impact on the tax relief available to many companies for their financing costs. The changes are aimed at private equity (PE) transactions but actually go far wider: impacting all corporate joint ventures and surprisingly bank debt regardless of the level of equity interest held by the lender. Indeed the rules can now apply where the lender has no equity interest at all. This represents a fundamental change in the concept of transfer pricing which until now has been...
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Anneli Collins Head of International & Finance Tax and Michelle Quest Private Equity tax partner KPMG report on the impact of the transfer pricing changes in the Finance Bill for corporate and PE deals
On 4 March the Revenue announced transfer pricing changes which will have a significant impact on the tax relief available to many companies for their financing costs. The changes are aimed at private equity (PE) transactions but actually go far wider: impacting all corporate joint ventures and surprisingly bank debt regardless of the level of equity interest held by the lender. Indeed the rules can now apply where the lender has no equity interest at all. This represents a fundamental change in the concept of transfer pricing which until now has been...
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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)")