TaxCorporate TaxBusinesses face global debt cap

Businesses face global debt cap

Treasury returns to restriction of interest relief idea as it drops 'passive income' proposals for foreign profits.

A global debt cap could be introduced for multi-nationals to limit the
possibility of abusing interest relief, it emerged yesterday.

As part of the government’s moves to overhaul the taxation of
multi-nationals, the Treasury raised the issue of returning to the idea of
restricting interest relief, whereby interest on UK debts can be offset against
profits.

The government said it was postponing its plans to drop the taxation of
inbound dividends, saying that the move, without corresponding anti-avoidance
measures, could cost the UK up to £1.1bn by 2012/13.

Businesses only pay £300m in taxes on inbound dividends, but the fear is the
move could also leave the government open to abuse.

‘The nature of some of the risks, especially from aggressive avoidance
schemes, means it is not possible to set an upper limit on them,’ the Treasury
added.

The government plans to work on the plans again, with one plan being to
introduce a debt cap.

It said: ‘The aim of the worldwide debt cap is to target situations where a
UK group bears more debt than is required to finance the worldwide group. In
addition this measure could provide an effective means of targeting many
‘upstream’ loans to the UK, which are used to repatriate overseas cash. However,
in order to protect those groups that are temporarily cash-rich the Government
would intend to allow the worldwide debt cap measure to be set aside where a
group is in a short-term cash rich position (e.g. following a sale).’

It is dropping plans to target ‘passive’ income, where multi-nationals’
foreign subsidiaries generate income from assets that are arguably UK assets
artificially located offshore for tax reasons.

‘The Government sees attraction in exploring improvements to the entity-based
model as an alternative to focusing on developing an income-based model,’ it
said.

Further Reading:

Read
the Treasury’s update on foreign profits moves

Related Articles

Big names, little tax: Airbnb, Facebook, Kellogg’s, eBay

Corporate Tax Big names, little tax: Airbnb, Facebook, Kellogg’s, eBay

2m Alia Shoaib, Reporter
New trading allowance: simplicity, but not as we know it

Administration New trading allowance: simplicity, but not as we know it

2m Emma Rawson, ATT Technical Officer
EU divided over radical tax reforms targeting tech giants

Corporate Tax EU divided over radical tax reforms targeting tech giants

2m Alia Shoaib, Reporter
‘Improve rather than lose’ disincorporation relief, tax body urges

Administration ‘Improve rather than lose’ disincorporation relief, tax body urges

3m Austin Clark, Reporter
How to educate your clients about tax avoidance

Corporate Tax How to educate your clients about tax avoidance

3m Clear Books | Sponsored
CGT clampdown nets HMRC £124m – but could lead to increase in use of avoidance schemes

Corporate Tax CGT clampdown nets HMRC £124m – but could lead to increase in use of avoidance schemes

3m Austin Clark, Reporter
‘Google tax’ nets HMRC £281m

Corporate Tax ‘Google tax’ nets HMRC £281m

3m Emma Smith, Managing Editor
Should I incorporate my buy-to-let business?

Corporate Tax Should I incorporate my buy-to-let business?

4m Emma Rawson