HMRC Consultations – July 2016

R3 responds to consultation requests from HMRC in relation to proposed changes in tax legislation which may have a negative impact in rescue and insolvency. Currently there are three open consultations in relation to:

• Reforms to Corporation Tax loss relief
• Tax deductibility of corporate interest expense
• Reform of the Substantial Shareholdings Exemption

The proposed restrictions to use of carried forward tax losses and interest relief restrictions, in particular, would have a major detrimental effect in both rescue and insolvency situations and R3 is in the process of drafting formal responses to all of the consultations.

Please contact Caroline Sumner at R3 (Caroline.Sumner@r3.org.uk) with any major concerns that you believe should be included in the R3 formal responses.

We also urge members to either respond directly or ensure that these concerns are reflected in their own Firm’s general response. The consultations can be found by clicking on the links below:

• Tax deductibility of corporate interest expense
• Reforms to corporate tax loss relief
• Reform of the substantial shareholders exemption