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UK Publishes Draft Legislation on Corporate Interest Restrictions and Relief for Carried-Forward Losses

30 January 2017

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Proposed Changes

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United Kingdom

UK HMRC has published draft legislation for provisions that will form part of the Finance Bill 2017 concerning corporate interest restrictions and relief for carried-forward losses. Corporate Interest Restrictions This legislation introduces a restriction on the amount of interest and other financing amounts that a company may deduct in computing its profits for Corporation Tax purposes. Interest deductions will be limited using a recommended Fixed Ratio Rule or an optional Group Ratio Rule. The Fixed Ratio Rule will limit the amount of net interest expense that a worldwide group can deduct against its taxable profits to 30% of its taxable...