Market leading insight for tax experts
View online issue

Debt cap consultation

printer Mail

HMRC invited comments by 22 November on draft regulations dealing with ‘mismatches’ between the tax and accounting treatment of interest and other financing expenses.

The current Finance Bill inserts a regulation making power into TIOPA 2010 Part 7, part of a package of measures arising from the review of the taxation of companies’ foreign profits.

HMRC's technical note indicates that a mismatch can arise where there is a difference between the financial liability of a group company disclosed in the accounts of the worldwide group and the amount of profit or loss brought into account under the loan relationships rules, or where a 'late interest' debit is treated as not accruing until it is paid.

EDITOR'S PICKstar
Top