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HMRC internal manual

Corporate Finance Manual

HM Revenue & Customs
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Debt Cap: anti-avoidance rules: main rules: excluded schemes: de minimis amount

Restructuring to get within the de minimis limits

A relevant company has a tested expense amount in excess of the de minimis limit of £500,000 arising from loans from other relevant companies but where the corresponding tested income amount due to the relevant companies are less than the de minimis limit. If the companies do not restructure the debt the debtor company will have a disallowance but the creditor companies will not be able to claim exemption for the interest income. In these circumstances the group may wish to restructure the debt to ensure that either the tested expense amount falls below the de minimis limit or that the tested income amount is in excess of the de minimis amount.