INTM413000 - Transfer pricing: the main thin capitalisation legislation: contents
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INTM413010Overview
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INTM413020Thin capitalisation legislation: Introduction
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INTM413030The 바카라 사이트śwould바카라 사이트ť and 바카라 사이트ścould바카라 사이트ť arguments
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INTM413040Summary of sections specific to thin capitalisation
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INTM413050Potential UK tax advantage
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INTM413060Transaction / series of transactions
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INTM413070Separate entity basis for determining borrowing capacity
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INTM413080The borrowing unit
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INTM413090UK바카라 사이트“UK thin capitalisation
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INTM413100Special rules for lending between companies
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INTM413110Guarantees 바카라 사이트“ what they do and what they are
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INTM413120Disregarding guarantees in working out the arm바카라 사이트™s length cost of debt
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INTM413130Establishing the arm바카라 사이트™s length value of a guarantee
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INTM413140Compensating adjustments for lenders
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INTM413150Removal of disallowed interest from obligation to deduct tax
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INTM413160Claims to compensating adjustments for guarantors
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INTM413170Interaction between claims by lenders and guarantors
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INTM413180The acting together rules
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INTM413190Treatment of interest when it is paid
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INTM413200Interest which exceeds the arm바카라 사이트™s length amount
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INTM413210Payments of yearly interest made overseas
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INTM413220Consequences of failing to deduct withholding tax
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INTM413230The interaction between UK taxing rights and double taxation agreements
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INTM413240Evolution of thin capitalisation legislation: pre 29 November 1994
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INTM413250Evolution of the thin capitalisation legislation: 29 November 1994 바카라 사이트“ 31 March 2004
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INTM413260Evolution of the thin capitalisation legislation: interest re-characterised as a distribution