The UK tax authorities, HM Revenue & Customs (“HMRC”), have issued a consultation document on possible changes to the rules requiring UK tax to be withheld from interest. Among other changes, the UK Government is proposing to disapply the quoted Eurobond exemption from UK withholding tax on interest where debt securities are issued intra-group and listed on a stock exchange on which there is no substantial or regular trading in the securities; it also proposes to remove the rule that allows UK source interest to be paid free of UK withholding tax where it is “short” interest (i.e. payable on a debt with a term of less than a year). We briefly examine the scope of the proposed changes and highlight some of the issues that arise.
View full memo, "UK Tax Authorities Consult on Possible Changes to UK Withholding Tax Rules"