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Tax Deductibility of Interest – What are the 3 biggest issues?

The Tax Deductibility of Interest in the context of real estate businesses and structures

What are the biggest and most pressing issues for business at the moment?

7 June 2025 | Authors: Mark Eade, Neil Insull

Mark Eade and Neil Insull explore the complex and evolving landscape of tax deductibility of interest within the real estate sector.

They focus on three critical issues affecting property businesses: transfer pricing, corporate interest restriction (CIR), and the unallowable purpose test, that have significant implications for how much interest can be deducted for tax purposes. Neil emphasises that, with the recent rise in interest rates, property businesses are paying considerably more on their debt, increasing the importance of maximising permissible tax deductions. They conclude by underscoring the evolving nature of the tax environment, encouraging businesses to review and possibly restructure their financing arrangements to ensure tax efficiency in the current climate.

If you would like to discuss any of the above, please speak to your usual Blick Rothenberg contact or Heather Powell our Property and Construction lead using the form below.

BR Mark Eade Neil Insull
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Heather Powell
Heather Powell
Partner, Head of Property and Construction
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