In July 2016 the Tax Department issued Circular 2016/10 aiming to provide further clarity on the definition of relevant terms and guidance on the practical application of NID. In summary, Circular 2016/10 provides the following:
- further guidance on the definitions of ‘new equity’ and ‘NID interest rate’;
- the introduction of scheduling for the purpose of applying the 80% cap;
- further guidance on relevant anti-avoidance provisions; and
- practical numerical examples for the application of NID.
More information can be found in the relevant newsletter here below:-