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CFCs and debt cap rules: draft regulations

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HM Treasury has published draft regulations amending the CFC and debt cap rules to ensure that the two regimes interact correctly.

‘The regulations [The Taxation (International and Other Provisions) Act 2010 (Part 7) (Amendment) Regulations 2013] ensure that the debt cap mechanisms for reducing or eliminating a corporation tax charge can also be applied, in appropriate circumstances, to a CFC charge. They do this by making sure that a CFC charge can be included as part of the allocated amount within the debt cap rules,’ the Treasury said.

Comments are invited by 21 November.