A4.424 Deduction of tax from yearly interestITA 2007, s 874 requires tax to be deducted from specified payments of yearly interest made: (a) by a company (b) by a local authority (c) by or on behalf of a partnership of which a company is a member; or (d) by any person to a person whose usual place of abode is outside the UKNeither (a) nor (b) applies where the payer is acting in a fiduciary or representative capacity1.This does not apply to such payments of yearly interest as are specifically excluded (see A4.425).For the purposes of (d) above, HMRC accept that a company which is non-resident under the case law central management and control test (see D4.103) may nevertheless have a usual place of abode in the UK,
ITA 2007, s 874 requires tax to be deducted from specified payments of yearly interest made:
(a) by a company
(b) by a local authority
(c) by or on behalf of a partnership of which a company is a member; or
(d) by any person to a person whose usual place of abode is outside the UK
Neither (a) nor (b) applies where the payer is acting in a fiduciary or representative capacity1.
This does not apply to such payments of yearly interest as are specifically excluded (see A4.425).
For the purposes of (d) above, HMRC accept that a company which is non-resident under the case law central management and control test (see D4.103) may nevertheless have a usual place of abode in the UK,
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