UK consultation on taxation of debt and derivatives

In early June 2013, HMRC launched a consultation on modernising the way in which the UK taxes corporate debt and derivatives. While a consultation in this area had been trailed in the UK’s 2013 Budget, the scope of the detailed proposals is surprisingly wide and, if the proposals are enacted, they will have significant impact on corporate taxpayers.

The two key drivers for the proposed changes appear to be HMRC’s ongoing programme to reduce the scope for tax avoidance and the forthcoming move to ‘new UK GAAP’ for UK companies which have not already adopted by International Financial Reporting Standards (IFRS), which will apply from 2015 at the latest. The document proposes an ambitious timetable, with certain avoidance-focused changes to be enacted next year in the Finance Act 2014, with the more structural changes waiting until 2015…

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