Fixed-ratio method: Difference between revisions

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imported>Doug Williamson
(Amend to 'profits'.)
imported>Doug Williamson
(Update post-CIR implementation in UK.)
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''Tax''.
''Tax - anti-avoidance''.


A proposal under the OECD's [[Base erosion and profit shifting]] (BEPS) initiative.
The fixed ratio method is a mechanism to limit corporate tax relief for interest and amounts economically equivalent to interest.


The fixed-ratio method is a proposed methodology to limit [[tax relief]] for interest and amounts economically equivalent to interest.
It limits the amounts eligible for relief to a percentage of a taxpayer's profits.


It would limit the amounts eligible for relief to a percentage of a taxpayer's profits.


 
Under the UK's Corporate Interest Restriction, with effect from April 2017:
An alternative proposed methodology is a worldwide interest cap.
*The fixed ratio for a large worldwide group is 30%
*The measure of profits the group's aggregate tax-EBITDA




==See also==
==See also==
* [[Common Consolidated Corporate Tax Base]]
* [[Common Consolidated Corporate Tax Base]]
* [[Corporate Interest Restriction]]
* [[Corporation Tax]]
* [[Corporation Tax]]
* [[Diverted profits tax]]
* [[Debt cap]]
* [[EBITDA]]
* [[Group]]
* [[Tax avoidance]]
* [[Worldwide interest cap]]
* [[Worldwide interest cap]]
* [[Tax avoidance]]
* [[Transfer pricing]]
* [[Double taxation]]

Revision as of 06:48, 2 May 2018

Tax - anti-avoidance.

The fixed ratio method is a mechanism to limit corporate tax relief for interest and amounts economically equivalent to interest.

It limits the amounts eligible for relief to a percentage of a taxpayer's profits.


Under the UK's Corporate Interest Restriction, with effect from April 2017:

  • The fixed ratio for a large worldwide group is 30%
  • The measure of profits the group's aggregate tax-EBITDA


See also