On 22 October 2015, the UK HMRC launched two public consultations, including on bringing interest expense deduction rules in line with the outcome of Action 4 of the OECD BEPS Project and bringing the patent box regime in line with Action 5 of the BEPS Project. The UK agrees with the recommendations developed under the BEPS Project and has launched the consultations to obtain input on how to best implement the needed changes. Interest Expense Deductions The basic recommendation of BEPS Action 4 is implementing a fixed ratio rule that allows an entity to deduct net interest expense up to...