WebThe fixed ratio debt cap This is the debt cap where the fixed ratio method applies (S400 (1)). It is the sum of two amounts: The group’s adjusted net group-interest expense... WebThe fixed ratio debt cap restriction is the means by which the modified debt cap is incorporated within the CIR rules. The equivalent modified debt cap restriction under the …

D1.1422 Calculating NGIE and ANGIE - LexisNexis

WebMay 30, 2024 · Basic framework – interest expenses of a group which would otherwise be deductible for UK corporation tax purposes in an accounting period will be restricted (i.e. cease to be deductible) to the extent that the net UK interest expenses of the group in that period exceed: 30 per cent of the group's UK tax EBITDA (the Fixed Ratio Rule), subject ... WebFixed Ratio Debt Cap (FRDC) Lower of: ANGIE Excess Debt Cap for Prior Period 30% of Aggregate tax- EBITDA £30m Fixed Ratio Debt Cap * £150m Basic interest allowance £30m Aggregate Tax Interest Expense £50m Total Disallowed Amount £20m greenheck sp a110 price

How to handle the new corporate interest restriction

WebGR debt cap (QNGIE) £150m: Interest capacity; £37.5m: ANTIE; £50m: Total disallowed amount £12.5m; Note that: (i) if the overseas parent was wholly equityfunded (with no … WebThe fixed ratio is the default limit and is set at 30 per cent of UK aggregate tax-EBITDA (30 per cent is the highest level contemplated in the OECD’s BEPS Action 4 report). … WebThe basic interest allowance under the fixed ratio method is the lower of the following amounts 1: • 30% × tax-EBITDA, and • the fixed ratio debt cap (generally, ANGIE) Assuming no brought forward amounts, the interest capacity in the UK would be the lower of the two amounts above, provided it is at least the de minimis amount 2. flutter text height behavior