Helen Lethaby and Jill Gatehouse (Freshfields Bruckhaus Deringer) explain what has changed in response to further representations on the draft legislation and where care needs to be taken now the rules are being introduced.
This article is a follow-up to an article published in February (Tax Journal 24 February 2017) which outlined the structure of the new interest barrier regime with reference to an interim draft of the legislation and highlighted some of the obvious and not-so-obvious problems with the proposed rules. The February article was necessarily selective in terms of which aspects of the rules it covered. (The legislation runs to over 150 pages – contrast this with the German interest barrier which takes up fewer than three pages of the German tax code – and the draft HMRC guidance to nearly 500 pages.) Now that the final (or substantively final) form of the legislation...
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Helen Lethaby and Jill Gatehouse (Freshfields Bruckhaus Deringer) explain what has changed in response to further representations on the draft legislation and where care needs to be taken now the rules are being introduced.
This article is a follow-up to an article published in February (Tax Journal 24 February 2017) which outlined the structure of the new interest barrier regime with reference to an interim draft of the legislation and highlighted some of the obvious and not-so-obvious problems with the proposed rules. The February article was necessarily selective in terms of which aspects of the rules it covered. (The legislation runs to over 150 pages – contrast this with the German interest barrier which takes up fewer than three pages of the German tax code – and the draft HMRC guidance to nearly 500 pages.) Now that the final (or substantively final) form of the legislation...
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:
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