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Practice guide: Mitigating UK withholding tax on debt

Deepesh UpadhyayBen JonesThe restricted bank lending environment of recent years has resulted in an increase in general and acquisition fund-raising through the issue of corporate bonds loan notes and other similar debt securities.

This shift has coincided with an increase in cash-rich investors from emerging economies and sovereign wealth funds resulting in many such debt securities being held by overseas investors.

Where interest-bearing debt securities are issued by a UK company to overseas investors there will be a basic obligation to apply UK withholding tax to interest payments made on such debt securities.

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