Draft UK interest measure omits key details

Tax professionals may have just two months to consider proposed new rules restricting corporate tax deductions for interest paid by many of the UK’s largest businesses. A measure to implement action 4 of the OECD’s base erosion and profit-shifting project is set out in draft finance bill clauses published for consultation on December 5 and intended to take effect from April 1, 2017, but many of the detailed rules may not be published until the end of January 2017 …

The draft legislation includes the core provisions setting out how a new fixed ratio rule and a modified debt cap would apply for most groups, and the rules for calculating the group ratio rule and the allocation of any restriction to companies in the group. But a number of provisions, including definitions for a group ratio rule and an exemption for investment in long-term infrastructure projects for the public benefit, may not be available until the end of January 2017.

Read more: My news story for Tax Analysts, December 5 (paywall).