Amendments to worldwide debt cap provisions
The Government intends to introduce further changes to worldwide debt cap for UK companies in the Finance Bill 2010.
The changes relate to the rules in Schedule 15, Finance Act 2009 and follow representations from interested parties since Finance Act 2009 became law.
The amendments will be set out in draft form as part of the 2009 Pre-Budget report. A detailed HMRC technical note has already been published. The main areas covered in the technical note are:
- Details of eleven proposed changes to be include in Finance Bill 2010
- Amendments to be dealt with via secondary legislation
- Further issues raised in consultation
o Accountancy mismatches in applying the main debt cap rules
o Deemed loan relationships
o Interaction with late interest rules
It is expected that the changes will take effect for worldwide accounting periods beginning on or after 1 January 2010.