| INTM542005 |
Definition of thin capitalisation |
| INTM542010 |
Thin capitalisation legislation: Introduction |
| INTM542012 |
The “would” and “could” arguments |
| INTM542015 |
Summary of sections specific to thin capitalisation |
| INTM542020 |
The basic precondition and the participation condition |
| INTM542030 |
Potential UK tax advantage |
| INTM542040 |
Transaction / series of transactions |
| INTM542050 |
Separate entity basis for determining borrowing capacity |
| INTM542060 |
The borrowing unit |
| INTM542070 |
UK-UK thin capitalisation |
| INTM542080 |
Special rules for lending between companies |
| INTM542090 |
Guarantees - what they do and what they are |
| INTM542100 |
Disregarding guarantees in working out the arm’s length cost of debt |
| INTM542105 |
Establishing the arm’s length value of a guarantee |
| INTM542110 |
TIOPA10/S182 - compensating adjustments for lenders |
| INTM542120 |
TIOPA10/S187 - the removal of disallowed interest from obligation to deduct tax under ITA07/S874 |
| INTM542130 |
TIOPA10/S192 - claims to compensating adjustments for guarantors |
| INTM542140 |
Interaction between claims by lenders and guarantors |
| INTM542150 |
The acting together rules |
| INTM542160 |
Treatment of interest when it is paid |
| INTM542170 |
Interest which exceeds the arm’s length amount |
| INTM542180 |
ITA07/S874 - payments of yearly interest made overseas |
| INTM542190 |
Consequences of failing to deduct withholding tax |
| INTM542200 |
The interaction between UK taxing rights and double taxation agreements |
| INTM542210 |
Evolution of thin capitalisation legislation: pre 29 November 1994 |
| INTM542220 |
Evolution of the thin capitalisation legislation: 29 November 1994 - 31 March 2004 |
| INTM542230 |
Evolution of the thin capitalisation legislation: interest re-characterised as a distribution |
| INTM542240 |
Table of origins of Part 4 of Taxation (International and Other Provisions) Act 2010 |
| INTM542250 |
Table of destinations to Part 4 of Taxation (International and Other Provisions) Act 2010 |
