Interest expense disallowed under the limitation
Interest expense disallowed under the limitation in any one year can be carried
forward for future offset without time limit.
Future offset starts in the first year
the limitation is not met by adding the amount brought forward to the interest
margin for that year. The same carry forward is available for excess EBITDA to
be calculated in retrospect from 2007. The interest, but not the EBITDA, carry
forward is subject to the same curtailment of loss carry forwards that ensue on a
change of shareholders.
Acquisition of over 50% of the capital of the company
by a single shareholder (and his related parties) destroys the carry forward
entirely; acquisition of between 25% and 50% curtails it in proportion to the
level acquired; acquisition of 25% or less is harmless.
EU Forecast
euf:ba18e:182/nws-01