Commentary

A4.446 Cross border interest payments

Administration and compliance

A4.446 Cross border interest payments

A4.446 Cross border interest payments

Where interest is paid to an overseas company, an application can be made by the lender for relief from UK tax (a reduction in the amount of UK tax that is deducted at source by the payee). Where the lender is resident in a country with which the UK has a double tax agreement, an application can be made for the payee to deduct tax at source at the 'treaty rate'. This may be as low as zero in some cases. The process of obtaining authority to apply the treaty rate of withholding tax can give rise to difficulties and delays in practice. HMRC have therefore introduced a number of schemes designed to simplify the process for the

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