United Kingdom: Withholding Tax

Private credit co-investment has evolved from a relationship benefit to a core product feature, driven by investor demand for enhanced returns, portfolio control, and stronger sponsor relationships. This article examines five structural alternatives for credit co-investment programs, analyzing how sponsors can optimize their approach based on execution certainty, regulatory considerations, and investor requirements.

The UK determines tax residence based on the Statutory Residence Test (SRT). While the rules can be complex, incorporating five Automatic Overseas Tests, four Automatic UK Tests, eight potential split year cases, and the sufficient ties test (with five possible ties), in many cases the outcome ultimately turns on a simple metric: the number of days spent in the UK.

There are a number of potential tax advantages when using FICs, including Inheritance Tax, but these will vary depending on the size

HM Revenue & Customs (HMRC) has paused operation of its long‑standing practice under which, where UK‑source yearly interest was paid gross to a treaty-entitled overseas lender before HMRC clearance was obtained, the borrower, ...

That section exempts certain foreign government investors (892 Investors) from US tax but, broadly, does not apply to commercial activity.

HMRC has confirmed it has paused a long‑standing concession that dealt with administrative failures to withhold income tax from payments of UK source yearly interest to overseas lenders.

Welcome to May's edition of the UK Tax Round Up. This month has seen three interesting tribunal decisions on the unallowable purpose test applied to intragroup

Welcome to April's edition of our UK Tax Round Up.

Tax legislation, and the decisions of tax courts and tribunals, can sometimes appear to be full of surprises.