Thin Capitalisation

HMRC has issued a draft Statement of Practice proposing an extension to the circumstances in which it will enter into pre-filing agreements in respect of the deductibility of interest on cross-border loans to which the UK's thin capitalisation rules could potentially apply. At the same time it has announced changes in its handling of treaty clearance applications for relief under double taxation agreements from UK source state taxation on interest payments. These changes will be of interest to multinational groups with an overseas ultimate parent which fund...