Worldwide interest cap: Difference between revisions

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imported>Doug Williamson
(Link with CBC reporting page.)
imported>Doug Williamson
(Update for Corporate Interest Restriction.)
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''Tax''.
''Tax - anti-avoidance''.


A proposal under the OECD's [[Base erosion and profit shifting]] (BEPS) initiative.
A proposal under the OECD's [[Base erosion and profit shifting]] (BEPS) initiative.


The worldwide interest cap method is a proposed methodology to limit [[tax relief]] for interest and amounts economically equivalent to interest.
The worldwide interest cap is a mechanism to limit [[tax relief]] for interest and amounts economically equivalent to interest.


It would limit the total amounts eligible for relief to a cap equal to the total of a taxpayer group's net third party interest expense.
The UK implemented a restriction with effect from April 2017, under its Corporate Interest Restriction.


The total cap would then be allocated by territory through an appropriate allocation key, for example territory profits as a proportion of total group profits.


 
An alternative methodology is a fixed-ratio method.
An alternative proposed methodology is a fixed-ratio method.




==See also==
==See also==
* [[Base erosion and profit shifting]]
* [[CbC reporting]]
* [[CbC reporting]]
* [[Common Consolidated Corporate Tax Base]]
* [[Common Consolidated Corporate Tax Base]]
* [[Corporation Tax]]
* [[Corporate Interest Restriction]]
* [[Diverted profits tax]]
* [[Fixed-ratio method]]
* [[Fixed-ratio method]]
* [[Tax avoidance]]
* [[Tax avoidance]]
* [[Tax relief]]
* [[Transfer pricing]]
* [[Transfer pricing]]
* [[Double taxation]]

Revision as of 06:14, 2 May 2018

Tax - anti-avoidance.

A proposal under the OECD's Base erosion and profit shifting (BEPS) initiative.

The worldwide interest cap is a mechanism to limit tax relief for interest and amounts economically equivalent to interest.

The UK implemented a restriction with effect from April 2017, under its Corporate Interest Restriction.


An alternative methodology is a fixed-ratio method.


See also