Martin Rybak and Jo Myers both Senior Consultants on Ernst & Young's Transfer Pricing team within International Tax Services assess HMRC's developing approach to intra-group financing arrangements
The aim of this article is to highlight some areas of difficulty for business in relation to intra-group financing arrangements and to show why such complexity may increase HMRC's scrutiny of interest deductibility. The article also considers how this may be managed by business.
Changing approach
In recent years HMRC has made a number of significant legislative and procedural changes in its approach to intra-group financing arrangements. In June 2007 it published a consultation document 'The Taxation of Foreign Profits' (Foreign Profits Review) which sets out further proposals which...
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Martin Rybak and Jo Myers both Senior Consultants on Ernst & Young's Transfer Pricing team within International Tax Services assess HMRC's developing approach to intra-group financing arrangements
The aim of this article is to highlight some areas of difficulty for business in relation to intra-group financing arrangements and to show why such complexity may increase HMRC's scrutiny of interest deductibility. The article also considers how this may be managed by business.
Changing approach
In recent years HMRC has made a number of significant legislative and procedural changes in its approach to intra-group financing arrangements. In June 2007 it published a consultation document 'The Taxation of Foreign Profits' (Foreign Profits Review) which sets out further proposals which...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
