The mismatch proposals in the Finance (No. 2) Bill 2016 Sch 10 (which inserts Part 6A into TIOPA 2010) contain additional provisions to expand the scope of the legislation to encompass permanent establishments, as announced by the chancellor in the Budget speech. These will particularly catch established financing structures used on both UK inbound and outbound investments. Affected groups should consider refinancing such arrangements as a matter of urgency, whilst recognising that the additional restrictions on interest deductibility that will take effect from April 2017 could complicate matters yet further.
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