Worldwide debt cap ― anti-avoidance

By Tolley

The following Corporation Tax guidance note by Tolley provides comprehensive and up to date tax information covering:

  • Worldwide debt cap ― anti-avoidance
  • The Gateway Test
  • The main body of the rules
  • The EEA exemption
  • The worldwide group test

Repeal of worldwide debt cap

The worldwide debt cap has been repealed from 1 April 2017 ― see the Worldwide debt cap ― main provisions guidance note for further information. This guidance note deals with the legislation in force before 1 April 2017.

TIOPA 2010, Part 7, Chapter 6 contains a targeted anti-avoidance rule which is very widely drafted and aimed at reversing the effects of any ‘schemes’ designed to achieve manipulation of four areas of the debt cap rules. These are set out below.

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