The US, EU member states and other countries have proposed and/or adopted a limitation rule for the deduction of interest by a corporate taxpayer. Will the OECD try to provide worldwide guidance for interest limitation? Is there an expectation for this guidance in the next several years?
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The new guidance is not meant to reflect a substantial change to UK law, but the requirement that tax advice is ‘likely to be correct’ imposes unrealistic expectations
China and a clutch of EU nations have voiced dissent after Estonia shot down the US side-by-side deal; in other news, HMRC has awarded companies contracts to help close the tax gap