Practice guide: Mitigating UK withholding tax on debt

Interest payable to overseas investors in UK debt securities such as corporate bonds and loan notes will be subject to UK withholding tax unless an exemption is applicable or the arrangements are structured to mitigate withholding tax. Common exemptions relied upon include relief under a double taxation treaty or ensuring the debt securities are quoted Eurobonds. Other common mitigation routes include structuring the securities as zero coupon discounted bonds or issuing the securities through a related company in a nil-withholding tax jurisdiction. Each route has advantages and disadvantages and the appropriate route will depend upon the relevant...