Interest Deductibility for Companies - Live at Your Desk

Introduction

The UK corporation tax regime has a number of overlapping rules which limit deductions for interest expense.

In the last few years, the rules have become even more complex following on from the work done at the OECD to try to tackle base erosion through its various BEPS workstreams. This will require careful attention for all companies, whether large or small.

This virtual classroom session will summarise the various UK regimes impacting interest relief to 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 capitalisation agreements
• The unallowable purpose tests (the TAAR and the RAAR)
• Brief background to the rules
• HMRC guidance
• Recent cases
• The late interest rules
• The corporate interest restriction (BEPS Action 4)
• Brief background - the debt cap, BEPS Action 4
• Key concepts in the new rules, including worldwide group, tax interest, tax- earnings before interest, taxes, depreciation, and amortisation (EBITDA)
• The ratios
• The fixed ratio rule
• 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
• Special rules for public infrastructure companies
• Other rules which might limit interest deductions: the hybrid mismatch rules, other specific anti-avoidance

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.