Corporate Interest Restriction – An Introduction to The Proposed RulesQuorum Training - A Wilmington Company
Corporate Interest Restriction – An Introduction to the Proposed Rules
This course will attempt to answer the following questions in relation to the interest restriction proposals: Why? What? Who? And How?
The “Why” session will consider why these proposals exist, the “What” session will explore the overarching approach to be followed, the “Who” session will look at the various definitions of companies that are included and the “How” session will explore in detail how the rules will operate.
Suitability - Who should attend?
Any tax professionals dealing with, or advising on, interest or interest-like expenses on which tax relief is claimed.
Outcome / Qualification etc.
CPD 6 hours
Training Course Content
- Background to proposals
- The UK experience
- The BEPS initiative
- The approach to be followed
- Treatment for groups
- Items/figures of interest i.e. tax EBITDA, Fixed ratio, Group ratio, tax interest, debt caps etc.
- Dealing with unused allowances in future periods
- Definitions of companies that are included
- Companies affected by restrictions
- Relationships/residency and the extent to which some companies may be in/out
- Group boundaries
- Individual companies potentially impacted
- Calculation of the ratios/capacity/allowances (including any b/f from prior years)
- Limitation of or reactivation of interest deductions and their allocation within/across the group
- The compliance framework regarding allocation and reporting and the level of flexibility available
The session will attempt to provide some decision trees and procedures/steps that should help companies formulate an approach that will enable them to compare results and decide which course of action may be appropriate.
- Public infrastructure
- Approach to foreign income covered by DTR
- Interactions with other reliefs (losses)
- Anti-avoidance provisions, compliance obligations regarding returns, deadlines, penalties and transitional issues
The price per place for this course is £595 plus VAT.
Contact Quorum Training for pricing details for running this course in-house. The price will include pre-course discussions with the trainer, supporting course materials and delivery of a practical, interactive course that meets your training needs.
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