In Hargreaves Property Holding Limited v HMRC [2021] TC08310, the First Tier Tribunal (FTT) found that despite extensive offshore loan restructuring, loan interest paid from profits arising from UK assets was from a UK source. It was subject to withholding tax on the payment to non-UK recipients.

On appeal, the FTT held that:

The HMRC assessments were upheld.

Useful guides on this topic

Companies: Permanent establishment & residence
What are the rules for determining a company's country of residence? What is central management and control? When does a company create a permanent establishment in another country?

Withholding Tax
When is Withholding Tax (WHT) paid? What are the applicable rates? Are there any exemptions?

External link

Hargreaves Property Holding Limited v HMRC [2021] TC08310

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