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Modernising the tax rules for debt and derivatives

Speed read

The proposed changes arising from the government’s review of the taxation of debt and derivatives are now taking shape. The changes range from fundamental structural reforms – such as focusing more strictly on the amounts recognised in profit and loss and clarifying the ‘fairly represents’ rule – to fortified anti-avoidance in the form of regime-wide anti-avoidance rules. Various technical changes will be made in relation to the connected companies rules; and there is a new general exemption introduced to facilitate corporate rescue.

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