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International Round-up

 
Chris Morgan Head of International Corporate Tax at KPMG in the UK rounds up the latest developments in the international tax world
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Foreign profits
 
At the time of writing the HMRC technical note providing an update on the worldwide debt cap proposals has just been released. The proposal now is to compare the net financing expense in the UK (tested amount) with the worldwide group's gross external finance expense (available amount). This should reduce the number of affected companies as a disallowance will now only arise in a company with net expense. Other key proposed changes include: excluding financial services groups totally; excluding forex and short term debt from the...
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