On 4 August 2017, UK HMRC published for consultation a second draft guidance on pending corporate interest restriction rules. The rules will be included in the UK's second Finance Bill for 2017 to be introduced in autumn 2017, and will apply from 1 April 2017.
The rules will operate on a worldwide group basis with a default fixed ratio method that imposes two main limits on the group's tax-interest deductions:
- The first is by reference to a fixed ratio of 30% of the taxable earnings before …