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Corporate interest restriction – draft regulations

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HMRC is consulting until 18 April 2017 on the draft Corporate Interest Restriction (Consequential Amendments) Regulations 2017, which make amendments necessary to ensure that collective investment vehicles and securitisation companies do not suffer unintended consequences from the new corporate interest restriction rules, which come into effect in April 2017.

The regulations make specific provision to exclude distributions by collective investment vehicles from the definition of ‘tax-interest expense amount’. They also treat the special retained profit figure for securitisation companies as the net ‘tax-interest income amount’, with adjustments for certain management fees.