INTM267780 - The attribution of capital to foreign banking permanent establishments in the UK: The approach in determining an adjustment to funding costs - STEP 5: Determining the capital attribution tax adjustment: contents

  1. INTM267781
    Disallowance of interest and other costs on funding equivalent to attributed equity - overview
  2. INTM267782
    Disallowance of interest and other costs on funding equivalent to attributed equity – an example
  3. INTM267783
    The range of capital attribution tax adjustment
  4. INTM267784
    Allowance for potential additional interest costs and other costs on loan capital attributed to a UK permanent establishment
  5. INTM267785
    Multi-currency books and the currency/interest rates to be used in arriving at the disallowances and allowances for equity and loan capital
  6. INTM267786
    Equity capital already allotted exceeding amount computed under the legislation
  7. INTM267787
    Equity capital attributed but no finding costs in the UK permanent establishment
  8. INTM267788
    Guarantee fees - no deduction available
  9. INTM267789
    Frequency of calculations
  10. INTM267790
    Allotment of capital