The Deductibility of Interest Expense in Anglo-American Countries : A Comparison and Review of Policy

Abstract

The deductibility of interest expense has been one of the most controversial issues in taxation law over the past decade, which raises the issue of modification. The purpose of this article is twofold. Firstly, to broadly analyse and compare the laws of a number of Anglo-American countries including Australia, Canada, New Zealand, the United Kingdom and the United States of America, which govern the deductibility of interest. Secondly, to review certain taxation policy arguments for either restricting or denying a deduction for interest in those Anglo-American countries. The study revealed that no coherent general principle of application in the area of the deductibility of interest was achievable in taxation law. Furthermore, a review of taxation policy in this area also revealed that interest incurred on borrowings of a private purpose represented the only restriction that should be placed on interest deductibility. Therefore, a general statutory approach may be the best solution to achieving this result.