INTM523410 | Thin capitalisation: practical guidance: accountancy issues: FRS 17: summary of the impact of FRS 17 on thin capitalisation

From HM Revenue & Customs · International Manual

The table below provides a high level overview of the likely impact of defined benefit scheme transactions on thin capitalisation measures.

CategoryCommentsRef
Periodic Costs--
Current service costRecognised as an expense of computing operating profit, so no adjustment required.INTM523270
Interest expenseNot treated as “interest” for thin capitalisation purposes. Adjustment therefore needed to deduct the interest expense of a defined benefit scheme from operating profit and exclude this interest from debt interest used in the interest cover ratio.-
Expected return on assetsAs above for “interest expense”.-
Actuarial gains and lossesShould be recognised in STRGL/OCI not profit and loss account/income statement, so should not impact on thin capitalisation covenants. If such amounts have been recognised in the income statement under IAS 19, then adjustments may be required for thin capitalisation purposes.-
Non-periodic costs--
Past service costsAdjust operating profit to remove these items if they are considered to be one-off items.-
Settlements and curtailmentsAdjust operating profit to remove these items if they are considered to be one-off items.-
Net scheme deficits/surplusesConsider actual facts of the case and impact on financial covenants.-