The Impact of TOFA on M&A Activity

The new Taxation of Financial Arrangements regime (‘TOFA’) will have significant effects for most large companies and trusts.  Those effects will not be limited just to transactions which involve the obvious financial instruments – the debt capital they raise and the cost of servicing it – TOFA can also have implications for the assets they acquire and the arrangements they put in place to manage risks associated with debt, equity, assets and liabilities.  In this Tax Brief, we look at some issues arising from how the TOFA rules will affect domestic and cross-border M&A activity.  For our full Tax Brief - click here