Interest double dip – Effect of anti-avoidance provisions

Business Tax

US Co. acquired UK Group in 2004, and a structure was put in place which allowed tax relief to be claimed in both the US and the UK in respect of interest on the financing costs.  Advice was sought on whether the structure was later caught by provisions introduced in the Finance (No. 2) Act 2005 to prevent avoidance involving tax arbitrage.

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