Worldwide debt cap ― reliefs

By Tolley

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

  • Worldwide debt cap ― reliefs
  • Group treasury companies
  • Short term finance
  • Stranded non-trading deficits (NTDs) and management expenses
  • EEA finance income

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The worldwide debt cap has been repealed from 1 April 2017 ― see the Worldwide debt cap ― main provisions guidance note for further information.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.

Groups that have to perform detailed debt cap calculations can take advantage of a number of specific reliefs designed to mitigate the effect of the rules in certain circumstances.

Each of these reliefs is available by election only, and all elections must be filed within three years of the end of the period of account of the worldwide group.

Group treasury companies

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