It has been a month of updates to previously announced measures and lengthy guidance, including on the corporate interest restriction, hybrids and other mismatches and revised GAAR guidance. The Finance Bill 2017, published on 20 March 2017, contains some helpful changes to the corporate interest restriction and SSE. The consultation document on the non-resident companies CGT charge confirms it is confined to UK source property income and gains chargeable to non-resident companies (and does not extend to trading income). The DTTPS is no longer restricted to corporate UK borrowers and to corporate lenders.”
This article was first published in the 21 April 2017 edition of Tax Journal
