Market leading insight for tax experts
View online issue

Withholding tax after Perrin and Ardmore

Speed read

Can interest that is paid by a person who is resident in the UK and who has no physical presence outside the UK nevertheless be non-UK source interest? In two recent cases, the First-tier Tribunal (FTT) said ‘no’ and delivered conservative decisions based on the multifactorial approach, an approach which is also supported by HMRC’s guidance. However, it seems that 43 years after the Bank of Greece case, there is still no agreement on what that case really says or on the extent to which the rules of private international law are relevant in this context. In Ardmore, the taxpayer’s argument for an entirely different approach failed.

If you are not a subscriber, subscribe now to read this content.
If you are already a subscriber, sign in
Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this article in full.