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
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INTM267781Disallowance of interest and other costs on funding equivalent to attributed equity - overview
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INTM267782Disallowance of interest and other costs on funding equivalent to attributed equity – an example
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INTM267783The range of capital attribution tax adjustment
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INTM267784Allowance for potential additional interest costs and other costs on loan capital attributed to a UK permanent establishment
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INTM267785Multi-currency books and the currency/interest rates to be used in arriving at the disallowances and allowances for equity and loan capital
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INTM267786Equity capital already allotted exceeding amount computed under the legislation
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INTM267787Equity capital attributed but no finding costs in the UK permanent establishment
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INTM267788Guarantee fees - no deduction available
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INTM267789Frequency of calculations
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INTM267790Allotment of capital