On 10 June 2021, the Labour Government opened up a five-week consultation period on the new interest deductibility rules.

They have released a Design of the interest limitation rule and additional bright-line rules discussion document which is lengthy and quite detailed, and reveals some interesting thinking, some of which I think is surprisingly taxpayer friendly.

On first look through the document, the following points are worthy of mentioning. Before going on, I stress that these are all proposals subject to feedback and finalisation (i.e. things could yet — and probably will — change).

Interest limitations will not apply to property…

Chas Gunaratne

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