Special Report on
Thin Capitalisation Issues
Thin Capitalisation Issues - Trends
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HM Revenue & Customs (HMRC) have released updated thin capitalisation guidance. Since the last guidance was released significant changes have occurred in borrowing trends and the wider economic environment. HMRC have taken the opportunity to establish their views on these issues. The guidance marks a change in the approach taken by HMRC with a shift in emphasis away from quantitative rules of thumb and definitive ratios (e.g. 1:1 debt to equity) to a more traditional detailed transfer pricing analysis based on the business plan, position within the industry sector, economic environment and rationale for debt ...
I hate it when I have to get all philosophical, but since China Tax Insights has thrown down the gauntlet, I feel I must. What is an international lawyer and what exactly do international lawyers do and what exactly should international lawyers do. Please bear with me here as I swear this post is going to be very relevant to more than just navel gazers and lawyers. Here goes. Matthew McKee over at China Tax Insights did a post, entitled, " What is an International Tax Lawyer? " His post was actually a riff on a post I did about a year ago where I stated the following about ... Read More
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- Thought Center - International Tax Talk Quarterly Series with ...
- Thought Center - ITS Global Dispatch, June 2010