The article reports that Her Majesty Revenue & Customs (HMRC) has started a consultation of the withdrawal of mortgage interest relief on home income plans, which were loans used to purchase life annuities. It defines a home income plan as a plan wherein the borrower takes out a loan ...
The recent decision of the UK Upper Tribunal inHM Revenue and Customs (HMRC) v Burlington Loan Management DAC (BLM)raises important issues around the proper interpretation of “anti-abuse” or “treaty shopping” clauses included in the context of a provision...
Where interest is paid in kind in the form of loan notes (referred to as PIK notes), HMRC is obliged to accept PIK notes in payment of the tax deducted. The March 2012 consultation On March 27, 2012, HMRC published a consultation covering several points relating to the taxation of interes...
HMRC manual changes: 10 January 2025 9 January 2025 HMRC names new Perm Sec 9 January 2025 HMRC are not appealing decisions on R&D subsidies and contracting out 7 January 2025 New guidance on refund claims for overpaid PAYE 7 January 2025 Digital platform operators reporting reminders...
A Chinese company has borrowed a USD500,000 loan from an overseas bank. Interest on the loan is accrued and paid annually at the rate of 12% per annum. The relevant business tax rate is 5% and neither surcharges nor treaty relief apply.What..