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Hot Topics in Thin Capitalisation

Ken Almand Director and David Sayers Partner Mazars LLP examine HMRC's latest views on thin capitalisation agreements and technical issues
It will not have escaped readers that the news is full of stories of plummeting profits wild currency fluctuations asset write-downs and cash flow problems. All of these potentially impact upon the rules that govern the level of related-party debt on which tax-deductible interest is allowable commonly referred to as thin capitalisation. Given that this is a highly topical tax issue for many groups of companies it is timely that HMRC has published its views on both technical and practical aspects of the subject.
The major part of this article is concerned with examining some of the key issues that HMRC has commented upon....

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