Critical treasury transactions: the tax implications

Maximising liquidity has been central to companies’ responses to Covid-19, and treasurers have been taking various actions accordingly. Unexpected tax liabilities could limit the effectiveness of such actions, and could arise from, for example: reduced interest deductibility; accounting profits from debt reorganisations; foreign exchange and fair value movements on financial instruments; and terminating or restructuring derivatives. This includes intragroup, as well as external, transactions. The pace of treasury transactions being entered into, and the current volatility in financial markets, means that it’s more important than ever for tax practitioners to be proactive in understanding treasurers’ objectives, and contribute to the design of transactions.