Five years after the launch of the first UK authorised contractual scheme (ACS) – also known as the UK tax transparent fund (UK TTF) – in 2014, there are 22 UK TTFs in the market, with 172 sub-funds amounting to billions of assets under management. Mariano Giralt, Christopher Mitchell and Gildine Cassou look at the scheme’s impact.
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Sweeping changes are headed for Germany’s TP system in the New Year. Tax teams will need to be well-prepared, say Andreas Katz and Anna Kupprion of Kreston Bansbach
Thin capitalisation rules limit the amount of debt deductions that can be claimed but regard must also be given to other income tax law provisions, the ATO said