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Practice guide: Financing and the debt cap

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Interest and other finance costs offer a valuable tax deduction but there are a number of restrictions and anti-avoidance provisions which need to be considered. In the UK, these include transfer pricng and thin capitalisation, late paid interest, unallowable purposes and from 1 January 2010 the worldwide debt cap. Multinational groups can ensure that financing is tax efficient by minimising withholding taxes on interest, and ensuring that interest receipts are not taxed at high tax rates. There are also several debt cap planning principles to consider.

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