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Debt Cap: Practical Problems

Mark Penney International Tax Partner KPMG identifies a number of practical problems resulting from the way the worldwide debt cap rules have been drafted
The Pre-Budget Report contained so-called worldwide debt cap rules which will have a significant impact on most UK groups as well as many foreign multinationals with UK subsidiaries. A summary of the debt cap rules is contained in an article by Martin Rybak and Jo Myers in Issue 961 (15 December 2008) of The Tax Journal. The purpose of this article is not to repeat a summary of the rules but rather to identify a number of practical problems resulting from the way the rules have been drafted.
Policy and economic considerations

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