Interest Deductibility for Companies - Live at Your Desk
The UK corporation tax regime has a number of overlapping rules which limit deductions for interest expense. In the last few years, these have grown significantly more complex and restrictive, and will require careful attention for large and small companies.
From BEPS to transfer pricing, this virtual classroom session will summarise the new regimes and bring you up to date.
What You Will Learn
This live and interactive session will cover the following:
- Summary of the different regimes
- Distribution treatment - outline of Part 23 CTA 2010 rules
- Transfer pricing
- How the rules evolved
- Current rules, and how they are applied
- Advance thin capitalization agreements
- The unallowable purpose test
- Background to the rules
- HMRC guidance
- The late interest rules
- Other rules which might limit interest deductions: the hybrid mismatch rules
- The post-2017 interest limitation rules
- Background - the debt cap, BEPS Action 4
- Key concepts in the new rules
- The fixed ratio rule: how it works
- The group ratio election and the group ratio (blended) election.
- The modified debt cap
- Special rules for public infrastructure companies
- Reporting and compliance: how it will work
- Interaction with other rules
- Impact on non-resident property companies from April 2020
Recording of live sessions: Soon after the Learn Live session has taken place you will be able to go back and access the recording - should you wish to revisit the material discussed.