This guidance note provides an introduction to the provisions governing the taxation of debt for UK companies and also provides links to more detailed guidance notes dealing with those provisions.
The taxation of corporate debt in the UK is complex. There are several different sets of rules governing the amount and timing of tax deductions available for interest and other amounts relating to corporate debt. These include:
- the loan relationships regime
- the corporate interest restriction (CIR) rules from 1 April 2017
- transfer pricing and thin capitalisation requirements
- the worldwide debt cap (WWDC) limitations before 1 April 2017 (incorporated in modified form into CIR from 1 April 2017)
- a range of associated anti-avoidance measures - it should be noted that there are regime anti-avoidance rules (RAARs) in CTA 2009, ss 455B-455D and related sections with effect from 18 November 2015 for loan relationships and in TIOPA 2010, s 461 applicable to the CIR.