On 12 May 2016, the UK Treasury issued a follow-up consultation on new rules concerning the tax deductibility of corporate interest expense in line with the guidelines developed as part of Action 4 of the OECD BEPS Project. The consultation seeks views on the detailed policy design and implementation of the new rules, which were announced as part of the UK Budget 2016. These rules include: A Fixed Ratio Rule limiting a group’s UK tax deductions for net interest expense to 30% of its UK EBITDA; A Group Ratio Rule based on the net interest to EBITDA ratio for the...