Worldwide interest cap - Revision history

imported>Doug Williamson: Update links.

2022-02-21T16:05:14Z

Update links.

← Older revision		Revision as of 16:05, 21 February 2022
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	==See also==		==See also==
	* [[Base erosion and profit shifting]]		* [[Base erosion and profit shifting]]
			* [[Business in Europe: Framework for Income Taxation]]
	* [[CbC reporting]]		* [[CbC reporting]]
	* [[Common Consolidated Corporate Tax Base]]
	* [[Corporate Interest Restriction]]		* [[Corporate Interest Restriction]]
	* [[Fixed ratio method]]		* [[Fixed ratio method]]

imported>Doug Williamson: Categorise.

2018-05-02T10:19:38Z

Categorise.

← Older revision		Revision as of 10:19, 2 May 2018
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	* [[Tax relief]]		* [[Tax relief]]
	* [[Transfer pricing]]		* [[Transfer pricing]]

			[[Category:Accounting,_tax_and_regulation]]

imported>Doug Williamson: Update for CIR.

2018-05-02T07:21:59Z

Update for CIR.

← Older revision		Revision as of 07:21, 2 May 2018
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	''Tax - anti-avoidance''.		''Tax - anti-avoidance''.

	A ~~proposal under~~ the OECD's Base erosion and profit shifting (BEPS) initiative.		A recommendation of the OECD's Base erosion and profit shifting (BEPS) initiative.

	~~The~~ worldwide interest cap ~~is a mechanism to limit~~ tax relief for interest and amounts economically equivalent to interest.		A worldwide interest cap limits corporate tax relief for interest and amounts economically equivalent to interest.

	The UK implemented a restriction accordingly with effect from April 2017, under its Corporate Interest Restriction.		The UK implemented a restriction accordingly with effect from April 2017, under its Corporate Interest Restriction.

imported>Doug Williamson: Mend link.

2018-05-02T06:41:11Z

Mend link.

← Older revision		Revision as of 06:41, 2 May 2018
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	* [[Common Consolidated Corporate Tax Base]]		* [[Common Consolidated Corporate Tax Base]]
	* [[Corporate Interest Restriction]]		* [[Corporate Interest Restriction]]
	* [[Fixed-ratio method]]		* [[Fixed ratio method]]
	* [[Tax avoidance]]		* [[Tax avoidance]]
	* [[Tax relief]]		* [[Tax relief]]
	* [[Transfer pricing]]		* [[Transfer pricing]]

imported>Doug Williamson: Update post-CIR implementation in UK.

2018-05-02T06:40:12Z

Update post-CIR implementation in UK.

← Older revision		Revision as of 06:40, 2 May 2018
Line 1:		Line 1:
	''Tax - anti-avoidance''.		''Tax - anti-avoidance''.

	A proposal under the OECD's [[Base erosion and profit shifting]] (BEPS) initiative.		A proposal under the OECD's Base erosion and profit shifting (BEPS) initiative.

	The worldwide interest cap is a mechanism to limit [[tax relief]] for interest and amounts economically equivalent to interest.		The worldwide interest cap is a mechanism to limit tax relief for interest and amounts economically equivalent to interest.

	The UK implemented a restriction with effect from April 2017, under its Corporate Interest Restriction.		The UK implemented a restriction accordingly with effect from April 2017, under its Corporate Interest Restriction.


	~~An alternative methodology is a fixed-ratio method~~.

imported>Doug Williamson: Update for Corporate Interest Restriction.

2018-05-02T06:14:28Z

Update for Corporate Interest Restriction.

← Older revision		Revision as of 06:14, 2 May 2018
Line 1:		Line 1:
	''Tax''.		''Tax - anti-avoidance''.

	A proposal under the OECD's [[Base erosion and profit shifting]] (BEPS) initiative.		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.		The worldwide interest cap is a mechanism 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 UK implemented a restriction with effect from April 2017, under its Corporate Interest Restriction.

	~~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 methodology is a fixed-ratio method.
	An alternative ~~proposed~~ methodology is a fixed-ratio method.


	==See also==		==See also==
			* [[Base erosion and profit shifting]]
	* [[CbC reporting]]		* [[CbC reporting]]
	* [[Common Consolidated Corporate Tax Base]]		* [[Common Consolidated Corporate Tax Base]]
	* [[~~Corporation Tax]]~~		* [[Corporate Interest Restriction]]
	* [[Diverted profits tax]]
	* [[Fixed-ratio method]]		* [[Fixed-ratio method]]
	* [[Tax avoidance]]		* [[Tax avoidance]]
			* [[Tax relief]]
	* [[Transfer pricing]]		* [[Transfer pricing]]
	* [[Double taxation]]

imported>Doug Williamson: Link with CBC reporting page.

2017-05-14T14:23:57Z

Link with CBC reporting page.

← Older revision		Revision as of 14:23, 14 May 2017
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	==See also==		==See also==
			* [[CbC reporting]]
	* [[Common Consolidated Corporate Tax Base]]		* [[Common Consolidated Corporate Tax Base]]
	* [[Corporation Tax]]		* [[Corporation Tax]]

imported>Doug Williamson: Punctuation.

2015-06-15T20:24:06Z

Punctuation.

← Older revision		Revision as of 20:24, 15 June 2015
Line 1:		Line 1:
	''Tax''		''Tax''.

	A proposal under the OECD's [[Base erosion and profit shifting]] (BEPS) initiative.		A proposal under the OECD's [[Base erosion and profit shifting]] (BEPS) initiative.

imported>Doug Williamson: Create the page. Source: The Treasurer, June 2015, page 10, Technical Briefing.

2015-06-15T07:46:04Z

Create the page. Source: The Treasurer, June 2015, page 10, Technical Briefing.

New page

''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.

==See also==

* [[Common Consolidated Corporate Tax Base]]
* [[Corporation Tax]]
* [[Diverted profits tax]]
* [[Fixed-ratio method]]
* [[Tax avoidance]]
* [[Transfer pricing]]
* [[Double taxation]]