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Hargreaves in the Court of Appeal: a return to orthodoxy on withholding taxes?

Speed read
The Court of Appeal has dismissed Hargreaves’ appeal against the Upper Tribunal’s decision and determined that tax should have been withheld from interest paid on loans advanced to the group. The judgment provides taxpayers and their advisers with helpful certainty on the meaning of ‘beneficial entitlement’ for withholding tax purposes and a great re-cap of key case law and their relevance for considering ‘beneficial entitlement’ and ‘yearly interest’ in the context of UK withholding tax.

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