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Corporate interest restriction: a structural flaw

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The new limitation on corporate interest deductions is coming into force from 1 April 2017. This rule will combine the OECD’s recommendations from Action 4 of its BEPS programme with the effect of the existing worldwide debt cap. The implementation of these two elements, as currently set out in the draft Finance Bill provisions, renders the carry-forward of restricted interest ineffective for some companies, exposing them to greater risk from volatility. The companies affected present low BEPS risk and the impact is not proportionate. We suggest an alternative implementation to avoid the conflict.

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