The worldwide debt cap is a complicated set of rules, from which a number of practical issues and planning opportunities arise. Five key practical issues to consider are: (1) mismatches as a result of the de minimis rules; (2) problems identifying the group and its relevant companies; (3) strategies for clearing intercompany loans; (4) replacing interest with other payments to ensure the debt cap rules do not apply; and (5) practical difficulties resulting from the two targeted-anti-avoidance rules.
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