Tax analysis: The First-tier Tax Tribunal has concluded that UK interest deductions can be denied under the ‘unallowable purposes’ rules (the statutory successor of paragraph 13 Schedule 9 Finance Act 1996) where they were incurred on intra-group debt which formed part of a hybrid mismatch structure for funding the US subgroup of a UK multinational. This structure aimed to erode the US tax base of the subgroup without giving rise to UK interest income.
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