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Withholding tax after Perrin and Ardmore

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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.

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