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F1 tax bill set to soar as HMRC changes the law

The Formula One season reaches its climax in Abu Dhabi on Sunday.

The organisers are calling it "the duel in the desert" - Lewis Hamilton vs Nico Rosberg for the championship title. A global audience of more than 400 million people will be watching.

  • Video report by ITV News business editor Joel Hills:

Formula One's popularity is a reminder that its more than just a sport, it's also a lucrative business.

The scale of the broadcast rights, the sponsorship deals, the advertising revenues have persuaded Liberty Media to pay more than £3.3 billion for F1.

When Liberty Media announced the deal in September, the company made it clear F1's tax structure was part of the attraction.

Albert E Rosenthaler, then Liberty's chief tax officer, told investors that F1's owners CVC Capital Partners had done a "wonderful job in terms of creating a structure that is extremely tax efficient. We will be stepping into that structure".

An investigation by ITV News has found that an agreement with HMRC - all perfectly legal - has allowed Formula One to pay an effective rate of Corporation Tax rate in Britain of 3.3 per cent over the last decade.

The official rate over the same period was 25.8 per cent.

Credit: PA

Liberty Media warned its shareholders in September that the British government was considering changing the tax law but reassured them the changes were likely to lead to only a "modest increase" in Formula One's tax bill here.

Tonight the Treasury has confirmed to ITV News that from April it will limit the amount of interest relief large companies can claim to 30 per cent of UK earnings. The legislation is drawn up and will be published on December 5.

We calculate that had such a cap been in place last year, Formula One's bill in Britain would have been £52m, instead of the £5m that was paid.

That hardly looks like a "modest increase".

£5m
the amount of UK tax paid by F1 last year
£52m
amount of UK tax that would have been paid by F1 had HMRC's new interest relief cap been in place

On the face of it, the government's decision to limit interest expense for all large corporates, in line with OECD recommendations of best practice, is set to increase tenfold the amount of tax F1 pays when its current agreement with HMRC expires at the end of 2017.

Liberty Media wouldn't comment on the calculations we've made - but neither does the company contest them.

Tonight, Liberty told us: "Our valuation of Formula One [at £3.3bn] included these tax changes, and we publicly disclosed this."

Liberty Media's shareholders have yet to vote on the F1 takeover - and the deal also has to be approved by the Competition and Markets Authority. There are no break fees if for any reason it doesn't proceed.

CVC Capital Partners, the current owners of Formula One, refused to comment.