Corporate Interest Restriction – An Introduction to the Proposed Rules

Speaker:  Nigel Waine  |  CPD Hours: 6.0

Price £595 plus VAT

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OBJECTIVES

This course will attempt to answer the following questions in relation to the interest restriction proposals: Why? What? Who? And How?

The “Why” session will consider why these proposals exist, the “What” session will explore the overarching approach to be followed, the “Who” session will look at the various definitions of companies that are included and the “How” session will explore in detail how the rules will operate.

CONTENT

Why?

  • Background to proposals
  • The UK experience
  • The BEPS initiative

What?

  • The approach to be followed
  • Limitations
  • Treatment for groups
  • Items/figures of interest i.e. tax EBITDA, Fixed ratio, Group ratio, tax interest, debt caps etc.
  • Restrictions
  • Dealing with unused allowances in future periods

Who?

  • Definitions of companies that are included
  • Companies affected by restrictions
  • Relationships/residency and the extent to which some companies may be in/out

How?

  • Group boundaries
  • Individual companies potentially impacted
  • Calculation of the ratios/capacity/allowances (including any b/f from prior years)
  • Limitation of or reactivation of interest deductions and their allocation within/across the group
  • The compliance framework regarding allocation and reporting and the level of flexibility available

The session will attempt to provide some decision trees and procedures/steps that should help companies formulate an approach that will enable them to compare results and decide which course of action may be appropriate.

Other Issues

  • Public infrastructure
  • Approach to foreign income covered by DTR
  • Interactions with other reliefs (losses)
  • Anti-avoidance provisions, compliance obligations regarding returns, deadlines, penalties and transitional issues

WHO SHOULD ATTEND

Any tax professionals dealing with, or advising on, interest or interest-like expenses on which tax relief is claimed.

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