Q&As

Where a ‘qualifying annual payment’ is made by a UK company to UK corporate trustees of a discretionary trust, can the UK company payer rely on the exemption from UK withholding tax in section 933 of the Income Tax Act 2007? Is that payment made ‘by or through’ the trustees for the purposes of withholding tax?

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Published on LexisPSL on 05/06/2019

The following Tax Q&A provides comprehensive and up to date legal information covering:

  • Where a ‘qualifying annual payment’ is made by a UK company to UK corporate trustees of a discretionary trust, can the UK company payer rely on the exemption from UK withholding tax in section 933 of the Income Tax Act 2007? Is that payment made ‘by or through’ the trustees for the purposes of withholding tax?

Where a ‘qualifying annual payment’ is made by a UK company to UK corporate trustees of a discretionary trust, can the UK company payer rely on the exemption from UK withholding tax in section 933 of the Income Tax Act 2007? Is that payment made ‘by or through’ the trustees for the purposes of withholding tax?

The withholding tax exemption in section 933 of the Income Tax Act 2007 (ITA 2007) applies only where the person ‘beneficially entitled to the income in respect of which the payment is made’ is a UK tax resident company. Consequently, the UK

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