Interaction between CFC rules and worldwide debt cap rules – draft regulations published

On 24 October 2012, HMRC published draft regulations on the interaction between the new CFC regime (introduced by Finance Act 2012) and the worldwide debt cap regime.
Broadly, the worldwide debt cap regime serves to limit the extent to which the worldwide debt costs of a group may be allowed as a deduction for UK corporation tax purposes.
Where certain interest costs have been disallowed under the worldwide debt cap rules, there is a corresponding exemption from corporation tax for cer…