Withholding tax

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Practice notes
Unilateral relief, like double tax relief, aims to relieve double taxation. Subject to certain conditions being satisfied and specific limits,...
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9th Nov
Practice notes
Plant and machinery allowances are the most widely used form of capital allowance. Plant and machinery is often (wrongly) interpreted as if the terms...
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Produced in partnership with Martin Wilson 12th Jan
Practice notes
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 sale of all the shares...
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9th Nov
Practice notes
The reasons why a company might carry out a demerger, and the different ways in which a demerger may be structured, are described in Practice Notes:...
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Produced in partnership with Zoe Feller of Bird & Bird 12th Jan
Practice notes
This Practice Note describes the law and practice relating to elections under section 198 or 199 of the Capital Allowances Act 2001 (CAA 2001), which...
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Produced in partnership with Martin Wilson 12th Jan
Practice notes
It is standard market practice for loan agreements (also known as facility agreements), whether bilateral or syndicated, to:•prohibit a borrower from...
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Produced in partnership with Eloise Walker of Pinsent Masons 12th Jan
Practice notes
Coronavirus (COVID-19): HMRC has stated in its International Manual that if a financial institution cannot meet the FATCA reporting deadline of 31 May...
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Produced in partnership with Ali Kazimi and Chris Orchard of Hansuke Consulting Limited 12th Jan
Practice notes
This Practice Note explains:•what a determination in respect of direct tax (ie a direct tax determination) is•when HMRC might issue a direct tax...
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Produced in partnership with Philip Rutherford 12th Jan
Practice notes
Where a dispute is brought to an end by a payment of damages or compensation, whether under a court order or an out-of-court settlement agreement:•the...
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9th Nov
Practice notes
Overdrafts, term loans and revolving credit facilitiesThree common types of loan facility are:•overdrafts•term loans, and•revolving credit facilities...
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9th Nov
Practice notes
The regime for property authorised investment funds (PAIFs, or as HMRC use in regulations and their published guidance, Property AIFs)) was introduced...
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Produced in partnership with Martin Shah of Simmons & Simmons LLP based on material originally written by Charles Goddard of Rosetta Tax LLP 12th Jan
Practice notes
The value shifting rules are anti-avoidance provisions. They are similar to the rules applying to depreciatory transactions in that they target the...
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9th Nov
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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9th Nov
Practice notes
A management buyout, or MBO, involves the acquisition of a business by its existing management team usually with the help of private equity financing....
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9th Nov
Practice notes
The international movement of capital rules should be considered whenever:•any non-UK tax resident subsidiary (referred to in this note as a foreign...
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9th Nov
Practice notes
This Practice Note:•explains:◦the purpose of the tax indemnity clause that is normally found in a loan agreement, and◦that the standard drafting of...
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9th Nov

Most recent Withholding tax content

Practice notes
The UK's approach to withholding tax on royalties in domestic law was, historically, rather haphazard and inconsistent—withholding tax was applied...
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Produced in partnership with Anne Fairpo of Temple Tax Chambers 21st Apr
Practice notes
This Practice Note is only relevant to UK source payments of interest and/or royalties made before 1 June 2021 or, in certain circumstances, before 3...
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15th Apr
Practice notes
IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation period entered into following the UK’s...
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9th Apr
Practice notes
IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation period entered into following the UK’s...
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9th Apr
Practice notes
The double taxation treaty passport scheme (DTTP scheme) enables a borrower to apply for and obtain an expedited authorisation to pay UK source...
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9th Apr
Practice notes
For more information on the other types of exemptions and reliefs from UK withholding tax that are available, see Practice Note: Exemptions and...
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9th Apr
Practice notes
Unilateral relief, like double tax relief, aims to relieve double taxation. Subject to certain conditions being satisfied and specific limits,...
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9th Apr
Practice notes
Unless an exemption or a relief applies, a payment of yearly interest arising in the UK (ie with a UK source) is generally subject to UK withholding...
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9th Apr
Practice notes
IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation period entered into following the UK’s...
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9th Apr
Practice notes
Interest is an important concept in UK tax law. Specifically, an obligation to withhold UK income tax applies to payments of certain types of...
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9th Apr
Q&As
IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation period entered into following the UK’s...
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8th Apr
Practice notes
Unless an exemption or relief applies, payments of yearly interest that have a UK source are subject to UK withholding tax at the basic rate...
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Produced in partnership with Sarah Squires of Old Square Tax Chambers 9th Mar
Q&As
Are the payments ‘qualifying annual payments’?We assume that the payments meet the various case law tests for being ‘annual payments’ (in particular,...
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15th Feb
Q&As
We have assumed that you are referring to a situation where the UK resident individual has paid interest from which income tax should have been...
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15th Feb
Q&As
The rules introduced in Finance Act 2016 (FA 2016) that tax Profits from trading in and developing UK land (transactions in UK land) did not make any...
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29th Nov
Q&As
As set out in Practice Notes: UK withholding tax on yearly interest and Withholding tax on royalties, UK tax law generally requires the payer to...
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29th Nov
Q&As
Unless an exemption or relief applies, payments of UK source yearly interest (or amounts that are treated by tax legislation as payments of yearly...
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29th Nov
Q&As
The disguised interest rules apply to ‘returns economically equivalent to interest’. For income tax purposes, the rules state that these returns are...
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29th Nov
Q&As
Where there is an obligation to withhold tax on interest, that obligation arises when interest is paid.Generally, interest is paid when there is an...
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29th Nov

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