Worldwide interest cap
From ACT Wiki
Tax
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.
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 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 proposed methodology is a fixed-ratio method.
