Withholding tax

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Practice notes
VAT on composite suppliesSingle composite supplies vs multiple suppliesWhere a supply comprises a number of different elements with varying VAT...
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Produced in partnership with Martin Shah and Gary Barnett of Simmons & Simmons LLP 19th May
Practice notes
Commercial service charges—VAT implicationsThis Practice Note is about the VAT treatment of non-residential service charges. General positionService...
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Produced in partnership with Martin Scammell 19th May
Practice notes
Offshore receipts in respect of intangible property (ORIP)Since 6 April 2019, a person that is neither UK tax resident nor resident in a full treaty...
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19th May
Practice notes
FATCA in the UK—the UK:US Intergovernmental Agreement: an outlineIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit...
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Produced in partnership with Ali Kazimi and Chris Orchard of Hansuke Consulting Limited 19th May
Practice notes
Tax considerations on a loan agreement—the tax gross up clauseIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit...
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Produced in partnership with Eloise Walker of Pinsent Masons 19th May
Precedents
1 Withholding and grossing up 1.1 All sums payable under this [Agreement] by or on behalf of any party (for the...
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19th May
Practice notes
Taxation of UK LLPsA UK limited liability partnership (LLP) is a body corporate for company law purposes, but is generally taxed as though it were a...
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19th May
Practice notes
Section 198 and 199 elections on transactions involving real estateThis Practice Note describes the law and practice relating to elections under...
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Produced in partnership with Martin Wilson 19th May
Practice notes
Loan capital exemption from stamp dutyDebt which:•qualifies as loan capital (whether it is short or long-term debt), and•satisfies further conditions...
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19th May
Practice notes
The Budget and Finance Bill processThe Budget is a Parliamentary event at which the Chancellor of the Exchequer makes important announcements relating...
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19th May
Practice notes
Capital reduction demergersThe reasons why a company might carry out a demerger, and the different ways in which a demerger may be structured, are...
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Produced in partnership with Zoe Feller of Bird & Bird 19th May
Q&As
Corporate redomiciliation—can a non-UK company redomicile into the UK?It is possible for a non-UK incorporated company to redomicile to the UK....
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19th May
Practice notes
Why have a tax covenant?It is market practice for a tax covenant, also known as a tax deed, to form part of the transaction documents in respect of a...
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19th May
Practice notes
R&D capital allowancesFORTHCOMING CHANGE: At Spring Budget 2021, the government announced a wide-ranging review of research and development (R&D)...
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Produced in partnership with Anne Fairpo of Temple Tax Chambers 19th May
Practice notes
Transfer of a trade under common ownershipSometimes the restructuring of a business will involve a company transferring an existing trade to a...
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19th May
Practice notes
SDLT group reliefFORTHCOMING CHANGE relating to FA 2008, Sch 36: In its Tax Information and Impact Note (TIIN) on freeports, the government announced...
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19th May

Most recent Withholding tax content

Practice notes
What is interest?Interest is an important concept in UK tax law. Specifically, an obligation to withhold UK income tax applies to payments of certain...
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22nd Aug
Practice notes
UK withholding tax on yearly interestUnless an exemption or a relief applies, a payment of UK source yearly interest is subject to UK withholding tax...
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22nd Aug
Practice notes
Administration of UK withholding tax on yearly interest and other types of incomeThis Practice Note outlines the key administrative obligations,...
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19th Aug
Q&As
What is the quoted eurobond exemption?IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation period...
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16th Aug
Q&As
Does a UK resident company making qualifying annual payments to two UK corporate trustees of a discretionary trust with unknown beneficiaries need to...
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16th Aug
Q&As
Do the rules that tax profits from trading in and developing UK land affect the UK withholding tax rules?The rules introduced in Finance Act 2016 (FA...
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16th Aug
Q&As
Should UK income tax be withheld from royalty payments made by a UK company to a UK charity?As noted in Practice Note: Withholding tax on royalties,...
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16th Aug
Q&As
Where a discount on a bond is treated as disguised interest, does the deeming provision mean that income tax must be withheld at source from the...
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16th Aug
Q&As
Does UK withholding tax apply to the payment of dividends?As set out in Practice Notes: UK withholding tax on yearly interest and Withholding tax on...
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16th Aug
Q&As
Can a double tax treaty relief claim be made for withholding tax paid to HMRC in the form of a funding bond?Unless an exemption or relief applies,...
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16th Aug
Q&As
In circumstances where a UK resident individual is paying interest to a non-UK resident individual but withholding tax has not been deducted, is it...
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16th Aug
Q&As
When is interest paid for the purposes of withholding tax?Where there is an obligation to withhold tax on interest, that obligation arises when...
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16th Aug
Practice notes
Exemption from UK withholding tax on interest and royalty payments made to an associated EU resident company before 1 June 2021 [Archived]ARCHIVED:...
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15th Aug
Practice notes
Qualifying private placement exemption from withholding taxUnless an exemption or relief applies, payments of yearly interest that have a UK source...
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Produced in partnership with Sarah Squires of Old Square Tax Chambers 15th Aug
Practice notes
Unilateral relief for foreign taxUnilateral relief, like double tax relief, aims to relieve double taxation. Subject to certain conditions being...
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15th Aug
Practice notes
Withholding tax on royaltiesThe UK's approach to withholding tax on royalties in domestic law was, historically, rather haphazard and...
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Produced in partnership with Anne Fairpo 15th Aug
Practice notes
The double taxation treaty passport scheme (DTTP scheme)The double taxation treaty passport scheme (DTTP scheme) enables a borrower to apply for and...
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15th Aug
Practice notes
Applications for double tax treaty relief from UK withholding tax on interestFor more information on the other types of exemptions and reliefs from UK...
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15th Aug
Practice notes
The syndicated loan scheme (SLS)Unless an exemption or a relief applies, a payment of yearly interest arising in the UK (ie with a UK source) is...
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15th Aug

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