Financing

HMRC has updated its guidance on the corporate interest restriction and also set out how to appoint a reporting company under these rules.

We’re aware that HMRC is writing to taxpayers to inform them that new rules were introduced in 2017 in respect of hybrids, corporate interest restriction and corporate losses.

A number of elections under the CIR rules have a 31 March deadline. Here's a reminder of what you need to be making sure you have in hand.

Following the publication of the second set in January, we now have the complete set of the draft Finance Bill 2017 provisions on the corporate interest deductibility restrictions. The Finance Bill is expected to be enacted over the Summer but be effectiv...

Neil Anthony, senior tax manager, provides a short update for real estate investors on the changes to interest deductibility. For more information, please contact your usual PwC adviser 

The June general election meant that a number of key tax measures were removed from the first 2017 Finance Bill. Finance (No. 2) Bill, published today, re-introduced these, including the reform of corporate tax loss relief restrictions on the corporate interest deductibility, changes to the Substantial Shareholdings Exemption (“SSE” and bringing UK residential property within the scope of UK IHT for non-domiciliaries.

The new corporate interest restriction rules have now been in force for over a year. Our experience of the rules to date has taught us that the rules sometimes bite in unexpected ways, resulting in increased interest disallowance going forward, or the loss of tax attributes such as surplus interest allowances. It is particularly important that advice is taken on the impact of the rules when contemplating a transaction (e.g. purchase or sale of a company / companies or a business), refinancing or internal reorganisation of a group.