On 21 February 2017, UK HMRC published draft legislation: the Corporate Interest Restriction (Consequential Amendments) Regulations 2017. The amending regulations make provisions for collective investment vehicles (CIVs) and securitization companies to ensure the operation of the corporate interest restriction (CIR) rules do not give an unintended result in these entities. The CIR rules are introduced as part of the Finance Bill 2017 and include a deduction limit equal to 30% of EBITDA (Fixed Ratio Rule), as well as an optional Group Ratio Rule that provides higher relief for commercially highly leveraged groups. With respect to CIVs, existing tax rules deem...