The following Tax practice note provides comprehensive and up to date legal information covering:
IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation period entered into following the UK’s withdrawal from the EU. At this point in time (referred to in UK law as ‘IP completion day’), key transitional arrangements come to an end and significant changes begin to take effect across the UK’s legal regime. This document contains guidance on subjects impacted by these changes. Before continuing your research, see Practice Note: What does IP completion day mean for Tax?
The requirement to deduct tax from UK source interest payments (ie withholding tax) is one of the key factors to be considered in the context of a bond issue in the UK. Where a tax deduction is required, this is:
at best, a cash flow disadvantage, ie the UK tax withheld can be set off against other UK or foreign tax due on the interest received, and
at worst, a permanent cost, ie the bondholder does not pay tax or pays less tax than the amount withheld on the interest received and cannot reclaim the tax withheld
Clearly in either case a bondholder would rather receive the interest gross and, as a result, whether deduction of tax is going to be required on a bond is a very important consideration for the issuer of the bond and the managers or arrangers
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Coronavirus (COVID-19): The guidance detailing normal practice set out in this Practice Note may be affected by measures concerning process and procedure in the civil courts that have been introduced as a result of the coronavirus (COVID-19) pandemic. For guidance, see Practice Note: Coronavirus
This Practice Note is an archive of news from the Loan Market Association (LMA) on LMA documentation and related topics. It covers LMA updates from early 2013 to January 2016. For the latest LMA developments since January 2016, see Practice Note: Loan Market Association (LMA)—latest news on
This Precedent letter covers disclosure obligations under CPR 31. It does not apply to proceedings subject to the disclosure pilot scheme under CPR PD 51U. For guidance on the disclosure pilot scheme, see Practice Note: Business and Property Courts—the disclosure pilot scheme. For a client letter on
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