Significant recent cases post Steele's case (notably Spassked, Firth and Hart) and important Government announcements, prompt this timely re-focus on the character of interest and the criteria for its deductibility.
This seminar explored the latest cases and judicial exposition of the rules for deductibility of funding costs, taxation and product rulings, and legislation.
Topics covered included:
- the characteristics of interest (revisited)
- the required connection(s) for deductibility
- start-up, cessation and apportionment issues
- applying the rules to exotic instruments, capital protected loans and split loans.
The aim of the seminar was to rigorously analyse the principles of interest deductibility, with an emphasis on real-time issues of current concern, and particularly their relevance to prepayments of financing costs at year-end.