Commentary

A4.451 Payments qualifying for exemption from withholding tax under the EU Interest and Royalties Directive

Administration and compliance

A4.451 Payments qualifying for exemption from withholding tax under the EU Interest and Royalties Directive

A4.451 Payments qualifying for exemption from withholding tax under the EU Interest and Royalties Directive

For the latest New Development, see ND.1438.

A UK company is normally required to deduct income tax at the basic rate when making a payment of interest or royalty, and to account to HMRC1 for the tax deducted.

Where a payment qualifies for exemption under the UK domestic legislation which gave effect to the EU Interest and Royalties Directive, the company making the payment is not required to deduct tax and the company receiving the payment has no liability to income tax in respect of that

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